~tfort tbt jftbtral fCommuntcations Commission l»asbington, me
Jn re ) ) Request for Declaratory Ruling ) by Meredith Corporation ) ) MB Docket No. 14-150 and ) ) "Alternative PSJP Proposal" by ) PMCM TV, LLC, for KVNV(TV), ) Middletown Township, New Jersey )
To: The Chief, Media Bureau
JOINT REPLY COMMENTS OF TIME WARNER CABLE INC. AND CABLEVISION SYSTEMS CORPORATION
Pursuant to the Media Bureau's Public Notice, DA 14-1298 (rel. Sept 12, 2014), Time
Warner Cable Inc. ("TWC") and Cablevision Systems Corporation ("CSC") hereby submit the following joint reply comments on the above-referenced Request for Declaratory Ruling of
Meredith Corporation and "Alternative PSTP Proposal" of PMCM TV, LLC, licensee of Station
WJLP(TV) (formerly known as KVNV(TV)).
The issue at the heart of both Meredith's Declaratory Ruling request and PMCM's
Alternative PSIP Proposal is whether WJLP should be assigned PSIP channel 33 (as proposed by
Meredith) or the two-part PSTP channel starting with 3 .10 (as proposed by PMCM). The interest of TWC and CSC in this channel assignment dispute arises from the fact that it would be extremely disruptive· and confusing for cable subscribers if cable operators in the New York
OMA were required to begin carrying WJLP on cable channel 3 (thereby necessitating the relocation of other services) only to have to move the station (necessitating further movement of other channels) if it ends up being assigned PSIP channel 33. Recognizing that the public interest would not be served by the disruption and confusion
that would result if cable operators commenced carrying WJLP on one channel and then moved
it to another cable channel, the Media Bureau issued a "Deferral Order" on July 25, 2014,
excusing cable operators in the New York DMA from having to comply with PMCM's carriage
and channel positioning elections until 90 days after the date of a "final decision" regarding
WJLP's PSIP channel assignment. 1 PMCM filed an Application for Review of the Deferral
Order, arguing in part that, regardless of the outcome of the PSIP channel assignment issue,
WJLP is entitled to carriage on cable channel 3 because WJLP has been assigned off-air (or
"RF") channel 3.2 TWC and CSC jointly opposed PMCM's Application for Review,
demonstrating that the Commission's rules and precedents make clear that, following the digital
transition, a station's "off-air" channel for purposes of its must-carry channel assignment rights,
is the station's PSIP channel, not its RF channel. 3
As stated above, the issue raised by Meredith's Declaratory Ruling petition and PMCM's
Alternative PSIP Proposal is the assignment of WJLP's PSIP channel. However, PMCM has
chosen to devote a significant portion of its comments to a reiteration of its argument that WJLP
is entitled to cable carriage on channel 3 no matter what PSIP channel the station is assigned.
TWC and CSC will not repeat their rebuttal of this argument here; rather, TWC and CSC direct
the Bureau's attention to the aforementioned Opposition that TWC and CSC jointly filed with
1 letter from William T. lake, Chief. Media Bureau, to Tara M. Corvo, et al., DA- I 029 (rel. July 25, 2014). On October 23, 2014, the Media Bureau assigned WJLP PSTP channel 33 "for use on an interim basis." Letter from Hossein Hashemzadeh, Deputy Chief. Video Division, Media Bureau, to Donald J. Evans. et al., DA 14-1528 (rel. Oct. 23, 2014). This "interim" decision does not supersede or otherwise impact the relief granted by the Bureau's Deferral Order. 2 In re PMCMTV. LLC, Requests of Various Cable Television Operators to Defer Carriage ofSta tion KVNV(TV), FCC Facility ID No. 86537, Middletown Township, New Jersey, Application for Review (filed Aug. 25, 2014). 3 In re PMCM TV. LLC. Requests of Various Cable Television Operators to Defer Carriage ofStation KVNV(TV), FCC Facility ID No. 86537, Middletown Township, New Jersey, Opposition of Time Warner Cable and Cablevision Systems Corporation to Application for Review of PMCM TV, LLC (filed Sept. 9, 2014).
2 respect to PMCM's Application for Review of the Deferral Order.4 A copy of said Opposition is
attached hereto and incorporated by reference.
CABLEVISION SYSTEMS CORPORATION TIME WARN~ll CABLE INC. By: ~.GH-u . /4«b By: ~ l ) .0~ Tara M. Corvo 7' sethADaVfisOn Mintz, Levin, Cohn, Ferris, Glovsky Edwards Wildman Palmer LLP and Popeo, P.C. 1875 Eye Street, N.W. 701 Pennsylvania Avenue, N.W. Eighth Floor Washington, D.C. 20004 Washington, D.C. 20006 (202) 434-7300 (202) 939.7900 Its Attorneys Its Attorneys
Dated: October 29, 2014
Attachment AM 40193472.1
4 TWC and CSC also direct the Media Bureau's attention to the comments filed by Ion Media License Company, LLC in response to the Bureau's Public Notice (addressing PMCM's mistaken assertion that WJLP has a guaranteed right of carriage on cable channel 3).
3 CERTIFICAT E OF SERVICE
I, Glenda Thompson, hereby certify that on this 29th day of October 2014, I caused
copies of the foregoing Joint Reply Comments of Time Warner Cable Inc. and Cablevision
Systems Corporation, to be placed in the U.S. Postal Service, first class postage prepaid or, as noted below, sent by electronic mail to the following:
Chairman Thomas Wheeler* Joyce Bernstein Federal Communications Commission Video Division - Media Bureau 445 12th Street, S.W. Federal Communications Commission Washington, D.C. 20554 445 12th Street, S.W. Washington, D.C. 20554 (By email: [email protected])
Commissioner Mignon Clyburn* Michael D. Basile Federal Communications Commission Robert J. Folliard, 111 445 12th Street, S.W. Cooley LLP Washington, D.C. 20554 1299 Pennsylvania Avenue, N.W. Washington, D.C. 20004
Commissioner Jessica Rosenworcel* Eve R. Pogoriler Federal Communications Commission Covington & Burling LLP 445 12th Street, S.W. 1201 Pennsylvania Avenue, NW Washington, D.C. 20554 Washington, D.C. 20004
Commissioner Ajit Pai* Frederick V. Giroux Federal Communications Commission Davis Wright Tremaine LLP 445 12th Street, S.W. 1919 Pennsylvania Avenue, N.W. Washington, D.C. 20554 Suite 800 Washington, D.C. 20006-3401
Commissioner Michael O'Rielly* Anne Lucey Federal Communications Commission CBS Corporation 445 12th Street, S.W. 601 Pennsylvania Avenue, N.W Washington, D.C. 20554 Suite 540 Washington, D.C. 20004
Jonathan Sallet, General Counsel* Bill LeBeau Jacob M. Lewis, Associate General Counsel* Holland & Knight Office of General Counsel 800 17th Street, N.W. Federal Communications Commission Suite 1100 445 12th Street, S.W. Washington, D.C. 20006 Washington, D.C. 20554 Barbara Kreisman, Chief* Donald J. Evans Video Division -Media Bureau Harry F. Cole Federal Communications Commission Fletcher, Heald & Hildreth, P.L.C. 445 12th Street, S.W. 1300 N. 17th Street, 11th Floor Washington, D.C. 20554 Arlington, Virginia 22209
Paul Rotella Best Copy and Printing, Inc. President & CEO Portals II New Jersey Broadcasters Association 445 12th Street, S.W. Howard L. Green Broadcast House Room CY-B402 348 Applegarth Road Washington, DC 20554 Monroe Township, New Jersey 08831 (By email: [email protected])
*Via Hand Delivery •etort tbt jfeber11l ~ommunicattons Gtommission l811ibinl(ton, l)QC
In re ) ) PMCMTV,LLC ) ) Requests of Various Cable Television ) Operators to Defer Carriage of ) ACCEPtED/FlllO Station KVNV(TV), ) FCC Facility ID No. 86537, ) SEP ... Q20'4 Middletown Township, New Jersey ) Federal eommun!Olttums Commtsa Office ot the Seer~ TO: The Commission
OPPOSmON OF TIME WARNER CABLE INC. AND CABLEVISION SYSTEMS CORPORATION TO APPLICATION FOR REVIEW OF PMCM TV, LLC
Time Warner Cable Inc. (''TWC") and Cablevision Systems Corporation ("CSC")
(collectively referred to as "Joint Opponents") hereby submit their joint opposition to the above- captioned Application for Review filed by PMCM TV, LLC, licensee ofStation KVNV(TV).
For the reasons stated below, the Commission should deny the Application for Review and allow the Media Bureau's decision deferring the implementation of KVNV's must-carry channel position election to stand pending the final resolution of the underlying channel positioning dispute between PMCM and Meredith Corporation.
BACKGROUND
KVNV is a television station licensed to (and, to the best of Joint Opponents knowledge, currently operating in) Ely, Nevada on RF Channel 3. The Commission has approved the reallocation ofKVNV from Ely to Middletown Township, New Jersey. By letters dated June 6,
2014, PMCM notified TWC and CSC pursuant to Section 76.64(t)(4) of the Commission's rules that KVNV "will commence operation as a new television station in the New York, New York OMA during the week of August 4, 2014."1 PMCM's letters indicated that it was opting
mandatory carriage for KVNV on the cable systems operated by TWC and CSC in the New York
OMA for the election period ending December 31, 2014 and requested that TWC and CSC carry
KVNV on cable channel 3.
On June 12, 2014, CSC wrote to the Commission requesting an order allowing CSC to delay implementing PMCM's must carry and channel position requests pending resolution of a pending dispute .between PMCM and Meredith Corporation, licensee of WFSB, Hartford, CT, regarding PMCM's PSIP (or ''virtual") channel. Meredith and PMCM each claim the right to
PSIP channel 3. On July 11 , 2014, TWC filed a similar request for deferral of PMCM's must carry and channel positioning election with respect to TWC's New York DMA systems.
Emphasizing that it was in the public interest to minimize subscriber disruption, both TWC and
CSC argued that if they were required to implement PMCM's must carry channel position demands and Meredith then prevailed in its dispute over KVNV's use of PSIP channel 3, millions of customers would be subjected to the confusion and disruption attendant to multiple channel line-up changes involving KVNV and the other services that would have to be moved to accommodate carriage ofKVNV on its virtual channel number. Comcast Cable
Communications, Inc. and Turner Broadcasting System also filed in support of the requested deferral order.
By letter dated July 25, 2014, the Media Bureau granted the requests for deferral of
PMCM's must carry and channel positioning elections for KVNV.2 The Bureau's decision allows TWC, Cablevision and Comcast to defer implementing PMCM's elections until 90 days
1 Copies of PMCM's June 6, 2014 election letters are attached hereto as Exhibit A.
2 Letter from William T. Lake, Chief. Media Bureau, lo Tara M Corvo, el al., DA- 1029 (rel. July 25, 2014).
2 from the date of a final decision on KVNV' s virtual channel. 3 The Bureau stated that it anticipated issuing a decision without lengthy delay.4
Thereafter, on July 31, 2014, the Media Bureau convened a meeting between PMCM and
Meredith to discuss their virtual channel dispute. As a follow-up to that meeting, PMCM presented the Commission with an "Alternative PSIP Proposal" on August 8, 2014 and an
"Explanatory Supplement" to the Alternative PSIP Proposal on August 13, 2014. In light of omissions by PMCM in serving the Alternative PSIP Proposal and Explanatory Statement on all interested parties, the Bureau extended the deadline for responding to these filings until
September 12, 2014. On August 25, 2014, PMCM filed its Application for Review of the
Bureau'~ July 25, 2014 deferral order.
ARGUMENT
PMCM's Application for Review presents three questions to the Commission for review:
Does not PMCM have a stattitory right to have KVNV carried, pursuant to the must-carr}' provisions of the Communications Act, on cable systems within its market on the channel number c;m which KVNV is broadcast over the air?
Is not PMCM entitled, under Advanced Television Systems Committee (ATSC) Document A/65 (ATSC 65), to utilize its over-the-air RF Channel 3 as its "major channel" number in KVNV's Program and System Information Protocol (PSIP)?
Does not the Bureau Order deprive PMC of its absolute right to cable carriage through the routine notification process it has undertaken~ without undue delay or evasion by cable operators?5
The Joint Opponents are principally concerned with the first and third questions presented by PMCM and with ensuring that the Commission applies the correct legal standard in resolving this matter. However, as an initial matter, the Joint Opponents note that the second
4 Id. at 4.
' App. for Rev. at I.
3 question presented by PMCM's Application for Review presumes that the Bureau's July 25,
2014 decision constituted a decision on the merits of the dispute between PMCM and Meredith
over the correct interpretation of ATSC 65. In fact, the Bureau merely acknowledged that
PMCM and Meredith had put forward conflicting interpretations of ATSC 65 and that a decision ( ' resolving that conflict would be issued "without lengthy delay." In short, there is no order
rejecting (or accepting) PMCM's interpretation of ATSC 65 for the Commission to review and,
thus, PMCM's Application for Review is premature.
Asswning that PMCM's Application for Review is ripe for consideration, the answers to
the first and third questions that PMCM presents - the two questions most directly of interest to
the Joint Opponents - are as follows: (1) PMCM does not have a statutory right to be carried on
the cable channel that matches its over-the-air (RF) channel and (2) the "routine notification"
process does not give PMCM an "absolute right" to cable carriage.
As to the first question, while PMCM is correct that Section 614(b)(6) of the
Communications Act, 47 U.S.C. § 534(b)(6), states that the channel positioning options given to
a station electing must carry include carriage on the cable channel number on which the station is
broadcast over the air, PMCM .is mistaken in characterizing this as an "absolute" right. When
Congress enacted Section 614 in 1992, it also anticipated that the requirements of that section
might have to be modified to accommodate the advent of "advanced television." Thus, in
Section 614(b)(4)(B), Congress conferred on the Commission the express authority to "establish any changes in the signal carriage requirements of cable television systems" it deemed necessary as part of an advanced television transition.. The Commission exercised that authority in 2008
when it clarified that, for purposes of applying the channel positioning rules following the
transition of television broadcasting from analog to digital, a station's "over-the-air" channel
4 would be its PSIP channel (i.e., the charmel that an over-the-air viewer would tune on their
receiver to access the station), not the station's RF channel.6
Thus, PMCM has no "absolute right" to carriage on the cable channel number that
matches its RF channel assignment. Indeed, it has no "right" to carriage on that channel at all,
unless it also happens to be the station's PSIP channel number. See Gray Television Licensee,
LLCv. Zito Media, L.P. 28 FCC Red 10780, DA 13-1614 (July 23, 2013) at note 10 ("In its 2008
Declaratory Order concerning the carriage of digital broadcast ~ignals, the Commission stated
that for purposes of digital broadcasting channel positioning, a station's over-the-air broadcast
channel number is no longer identified by reference to its over-the-air radio frequency, but
instead to its Major Channel Number as carried in its PSIP") (emphasis added); KSQA• . L.L.C. v.
Cox Communications, Inc., 27 FCC Red 13185 (MB 2012) (rejecting broadcaster's claim that
post-digital transition, a station's must carry channel positioning options include not only the station's PSIP channel, but also its RF channel). Under the circumstances, the Bureau's decision to defer the implementation of PMCM's must carry channel positioning election until the dispute over KVNV's PSIP channel is finally resolved is consistent with the channel positioning rules and the policy (i.e., minimizing subscriber confusion) underlying those rules.7
6 Carriage ofDigital Television Broadcast Signals: Amendment to Part 76 ofthe Commission's Rules, Declaratory Order, 23 FCC Red 14254, 14258-59 (2008):
We clarify that any station carried pursuant to mandatory carriage may demand carriage on its major channel number as broadcast in the station's PSIP. We also clarify that although the First Report and Order did not specifically address the significance of the statutory provisions and rules with respect to the "historic" carriage options, these statutory options remain available to digital must-carry broadcasters, who will make digital channel placement elections pursuant to Sections 76.57(a) or (b) just as they previously have for analog channel placement elections. Section 76.57(c), adopted in the First Report and Order. should be read as clarifying the manner in which cable operators are to determine the channel number on which a local commercial or qualified NCE station is "broadcast over the air" when implementing such a station's election under Sections 76.57(a) or (b).
7 The underlying purpose of the channel positioning provision in the 1992 Act was to minimize the risk ofsubscriber con.fusion in locating a broadcast signal on the cable system. The substitution of the PSIP channel - the channel number used by over-the-air viewers to access the station -- for the RF channel as one of the channel positioning
5 Turning to the third question presented by PMCM in its Application for Review, there
simply is no support in the Communications Act or the Commission's rules for PMCM's
contention that by simply complying with the "routine notification" requirements for
communicating its must carry and channel positioning election it obtained an "absolute right" to
cable carriage consistent with the tenns of that notification. In fact, Section 614 of the
Communications Act expressly gives the Commission the authority to resolve must carry and
channel positioning disputes.8 Moreover, the Commission has long adhered to a policy of
staying carriage while such disputes are being adjudicated, holding that there is a strong public
interest in avoiding the subscriber disruption and cable operator costs caused if the operator has
to make and then reverse a channel line-up change.9 1bis, of course, is the same reasoning that
the Bureau applied in granting the requests for an order deferring the implementation of
PMCM's must carry and channel positioning requests pending resolution of dispute over
KVNV's PSIP channel.1° Finally, the 90-day deferral period that the Bureau granted to TWC,
options following the digital transition is consistent with that purpose as is deferring implementation of a disputed PSIP-based channel position demand. ·
1 See 47 U.S.C. § 534(b)(6)("Any dispute regarding the positioning ofa local commercial television station shall be resolved by the Commission'); see also 47 U.S.C. § 534(d) (procedures for resolving must carry disputes).
9 See, e.g., Petition ofTime Warner New York City Cabl~ Group for Modification ofADI for Station WMBC, 11 FCC Red 6514, DA 96-828 (CSB, 1996) at para. 30);
there is a strong public interest benefit in maintaining the status quo because it helps avoid unnecessary and unwanted subscriber confusion and disruption caused by possible channel line-up changes caused due to the addition of broadcast signals by the operator and subsequent Commission orders sanctioning the deletion of the same signal. In additional, [by maintaining the status quo), cable operators would be spared the unnecessary costs of notifying subscribers of channel line-up changes which, once a decision is rendered by the Commission, might change once again").
10 PMCM cavalierly asserts, without the slightest substantiation, that channel line-up changes occur frequently, causing only "minor' or "negligible" inconvenience for cable operators and their subscribers. App. for Rev. at 15- 16. It is clear, however, that the Commission disagrees, panicularly where, as here, there is a significant risk that a system impltimenting PMCM' s channel positioning request could subsequently be required to renrrange its line-up a second time. Moreover, TWC ond CSC both explained that extensive line-up rearrangements would be required if
6 CSC and Comcast is consistent with the 90-day period that the Commission's rules give a cable
operator to comply with a new station's must carry election and channel positioning request. 11
CONCLUSION
For the reasons stated above, the Commission should deny PMCM's Application for
Review.
CABLEVISION SYSTEMS CORPORATION TIME WARNER CABLE INC.
By: ~A rJA. tc.v't> &, By: ~~ Tara M. Corvo l Seth A. Davidson Mintz, Levin, Cohn, Ferris, Glovsky Edwards Wildman Palmer LLP and Popeo, P.C. 1875 Eye Street, N.W. 701 Pennsylvania Avenue, N.W. Eighth Floor Washington, D.C. 20004 Washington, D.C. 20006 (202) 434-7300 (202) 939-7900 Its Attorneys Its Attorneys
Dated: September 9, 2014
PMCM's request is granted - rearrangements that would involve significantly more than the "one or two stations" PMCM asserts are at issue. App. for Rev. at 14.
11 47 C.F.R .§ 76.64(t)(4) ("new television stations ... sha11 make their initial [must carry and channel positioning] election any time between 60 days prior to commencing broadcast and 30 days after commencing broadcast ... ; such initial election shall take effect 90 days after it is made"). Joint Opponents note that, notwithstanding PMCM's assertion that it gave the required notice of its must carry and channel positioning election in a " timely manner," App. for Rev. at 14, the above-cited rule required PMCM to perfect its election by commencing operations within 60 days of its June 6, 2014 election letters (i.e., by August 5, 2014). However, PMCM acknowledges in its Application for Review that it bas not yet commenced operations in the New York DMA and does not expect to do so until "mid-September." App. for Rev. at 4.
7 EXHIBIT 1 XV:NVV71'3 :MiddCetown 'Townsliip, :NJ
June 6, 2014
Via Certified Mail Return Receipt Requested
Time Warner Cab!~ 13820 Sunrise Valley Drive Herndon, VA 20171
Re: Maociatorv Caniage Election for KYNY. Middletown Township. NJ
Dear Sir or Madam: Pursuant to Section 614 of the Communications Act of 1934, as amended, ~d Section 76.64(f)(4) of the rules ofthe Federal C.~mmunicatioos Commissio~ titjs will inform you that Television Station· KVNV, Middletown Township, New Jersey (the . "Station") will commence operation as a Dew television station in the New Yor~ New York OMA during the week of AUgust 4, 2014.
PMCM TV, LLC, the licensee of the Station, bereby elects mandatory carri11ge of the Station's television signal pursuant to S~t:i~~t76.56,Cl?) on.all cabl~ systems ope.rated by Cablevision Systems Corp. or its subsidimj~ and1 aftili~tes serving the New York, New York DMA, including but not necessarily limited to; those set forth on Exhibit A hereto, for the election period endjng December 31. 2014. The Station is licensed to Middletown Township, New Jersey. which is located in Monmouth County, New Jersey and is part of the New Yorlc, New York DMA. KVNV will be broadcasting from 4 Times Square in New York City serving the entire New York OMA. The Station therefore is entitled to elect mandatory carnage on your system(s) under the rules of the FCC. Pursuant to Section 76.57 of the FCC's rules.
PMCM TV, LLC requests carriage of th~ Station, on Channel 3, its over-:ih~air channel number. As KVNV will be broadcasting HD m·120p we.ate also re~tfully requesting the station be simultaneously carried on the same corresponding number on the HD tier as is normally afforded other local f>roadcasters who have chosen on channel carriage.
(00.12061l I} Time Warner Cable June 6, 2014 Page 3of5
Exhibit A Cable Communities
CommLi11lb' Unit ID Communltv Name Coaatv State NJ0082 FORT LEE BERGEN NJ NJ0092 EDGEWATER BERGEN NJ NJ0203 RIDGEFIELD BERGEN NJ NJ0208 ENGLEWOOD CLIFFS BERGEN NJ NJ0232 CLIFFSIDE PARK BERGEN NJ NJ02Sl EN
Communltv Unit ID Community Name County State NY0773 HIGHLAND FALLS ORANGE NY NY0819 HIGHIANO <:>RANGE NY NYOB21 MIDDLETOWN <:>RANGE NY NY084S GOSHEN ORANGE NY NY0846 GOSHEN ORANGE NV NV0970 WAWAYANDA ORANGE NY NY1022 U:S MllfftARY ACADEMY ORANGE NY NY1088 OTlSVILlE O_RANGE NY NY1089 MOUNT HOPE OR'ANGE NY NY1090 HAMPTONBURGH ORANGE NY NY1648 CHESf.ER ORANGE NY NY1281 QUEENS clliJEENS NV NVl340 QUEENS QUEENS NY NY1312 STATEl'fl™.ND RIC::HMOND NY NY0161 J.EFF.E .RSONV.ILlE SULLIVAN ~y NYOl98 LIBERTY Stlll!IVA~ NY NY0225 RQS
Coinmuaitv Unit ID Commanitv Name Couatv State NY0437 El:LENVILLE ULSTER NY NY0438 ROCHESTER ULSTER NY NY0473 OLIVE ULSTER NY NY0481 SAUGERTIES UlsTER NY NY0494 MARBLETOWN UlSTER NY NV049S ROSENDALE ULSlER NY NVOSlS SHAWANGUNK ULSTER NY NYOSS6 SHANE>Al :KV:N11 'D'.TV 3 :Af.ic{c{{etown 'Townsfi!JJ, :NJ June 6, 2014 Via Certified Mail, Return Receipt Requested Cablevision Systems Co1p. 1111 Stewart A venue Bethpage, NY 11714 Attn: Adam Wienstein Re: Mandatory Carriage Election forKVNV. Middletown Township. NJ Dear Mr. Wienstein: Pw·suant to Section 614 of the Communications Act of 1934, as amended, and Section 76.64(f)(4) of the rules of the Fedel'al Communications Commission, this will inform you that Television Station KVNV, Middletown Township, New Jersey (the "Station") ~ill com1lience operation as a new television station in the New York, New York DMA during the week of August 4, 2014. PMCM TV, LLC, the licensee of the Station, hereby elects mandatory carriage of the Station's television signal pursuant to Section 76.56(b) on all cable systems operated by CabJevision Systems Corp. or its subsidiw:ies and affiliates serving the New York, New York DMA, including but not necessarily limited to, those set forth on Exhibit A hereto, for the election period ending December 31, 2014. The Station is licensed to Middletowtt Township, New Jersey, which is located in Monmouth County, New Jersey and is part of the New York, New York.OMA. KVNV will be broadcasting from 4 Times Square in New York City serving the entire New York DMA. 1l1e Station therefore is entitled to elect mandaLory carriage on your system(s) lmder the rules of the FCC. Pursuant to Section 76.57 of the FCC's rules. PMCM TV, LLC requests caniage of the Station on Channel 3, its over-the-air channel number. As KVNV will be broadcnsting HD in 720p we are aJso respect.fully requesting the station be simultaneously can-ied on the same corresponding nwnber on the HD tier as is normally afforded 0U1er local broadcasters who have chosen on channel carriage. 100JlC61S·I ) Cablevision Systems Corp. June 6, 2014 Page 2of12 The station's cont~ct pel'son and address for purposes of receiving official cor1·espondence is as follows: KVNV DTV 3 Middletown Township, NJ 1329 Campus Parkway Neptune, NJ 07753 Attention: Lee Leddy Office# (732) 403-3875 Email: [email protected] Please contact the undersigned if you should have any questions concerning this matter. Sinc€;rely, /.!:.A~ll/L Managing Member, PMCM TV LLC Cell: (908) 433-0490 [email protected] cc: Cablevision Systems Corp. One Media Crossways Woodbury, NY 11797 Cablevision Systems Corp. June 6, 2014 Page 3of12 Exhibit A Cable Communities Conimuoitl' Unit ID Communitv Name County State CTOOSS BRIDGEPORT FAIRFIELD CT CT0056 STRATFORD FAIRFIELD CT CT0114 FAIRFIELD FAIRFIELD CT CT0115 DARIEN FAIRFIELD CT CT0116 EASTON FAIRFIELD CT CT0117 GREENWICH FAIRFIELD CT CT0118 NEW CANAAN FAIRFIELD CT CT0119 NORWALK FAIRFIELD CT CT0120 REDDING FAIRFIELD CT CT0121 STAMFORD FAIRFIELD - CT CT0122 WESTON FAIRFIELD CT CT0123 WESTPORT FAIRFIELD CT CT0124 WILTON FAIRFIELD CT NJ0034 OAKLAND BERGEN NJ NJ0195 RIDGEWOOD BERGEN NJ NJ0201 BOGOTA BERGEN NJ NJ0204 TEANECK .BERGEN NJ NJ0227 - GLEN ROCK BERGEN NJ N~0228 HACKENSACK BERGEN NJ NJ0244 MAYWOOD BERGEN NJ NJ0245 GARFIELD BERGEN NJ NJ0264 RIVER EDGE BERGEN NJ NJ0265 SADOLEBROOK BERGEN NJ NJ0266 WESTWOOD BERGEN NJ NJ0271 WASHINGTON BERGEN NJ NJ0276 SOUTH HACKENSACK BERGEN NJ NJ0313 RAMSEY BERGEN NJ NJ0315 ROCHELLE PARK BERGEN NJ NJ0326 WOODRIDGE BERGEN NJ NJ0331 HASBROUCK HEIGHTS BERGEN NJ NJ0341 ELMWOOD PARK BERGEN . NJ NJ0342 LODI BERGEN NJ NJ0349 WALDWICK BERGEN NJ NJ0403 WYCKOFF BERGEN NJ NJ0406 HOHOKUS BERGEN NJ NJ0409 ALLENDALE BERGEN NJ NJ0432 PARK RIDGE BERGEN NJ NJ0458 UPPER SADDLE RIVER BERGEN NJ NJ0477 MIDLAND PARK BERGEN NJ NJ0529 ALPINE BERGEN NJ NJ0532 FRANKLIN LAKES BERGEN NJ Cablevision Systems Corp. June 6, 2014 · Page 4of12 Communitv Unit ID Community Name County State NJ0421 MAHWAH BERGEN NJ NJ0489 MONTVALE BERGEN NJ NJ0145 BERGENFIELD - BERGEN NJ NJ0207 NEW MILFORD BERGEN NJ NJ0210 CRESSKILL BERGEN NJ NJ0211 DUMONT BERGEN NJ NJ0217 TENAFLY BERGEN NJ NJ0259 FAIRLAWN BERGEN NJ NJ0260 ORADELL BERGEN NJ NJ0293 DEMAREST BERGEN NJ NJ0311 PARAMUS BERGEN NJ NJ0373 HILLS.DALE BERGEN NJ NJ0374 CLOSTER BERGEN NJ NJ0375 EMERSON BERGEN NJ NJ0420 RIVER VALE BERGEN NJ NJ0425 OLD TAPPAN BERGEN NJ NJ0426 WOODCLIFF LAKE BERGEN NJ NJ0448 HARRINGTON PARK BERGEN NJ NJ0449 NORWOOD BERGEN NJ NJ0450 NORTHVALE BERGEN NJ NJ0451 HAWORTH BERGEN NJ NJ0584 SADDL£ RIVER BERGEN NJ NJ0585 ROCKLEIGH BERGEN NJ NJ0176 CEDAR GROVE ESSEX NJ NJ0181 NORTH CALDWELL ESSEX NJ NJ0224 NUTLEY ESSEX NJ NJ0476 NEWARK ESSEX NJ NJOS82 SOUTH ORANGE ESSEX NJ NJ0083 NORTH BERGEN HUDSON NJ NJOlll HOBOKEN HUDSON NJ NJ0345 WEEHAWKEN HUDSON NJ NJ0365 WEST NEW YORK HUDSON NJ NJ0366 UNION HUDSON NJ NJ0381 BAYONNE HUDSON NJ NJ0233 MIDDLESEX MIDDLESEX NJ NJ0237 DUNELLEN MIDDLESEX NJ -NJ0239 ED ISON MIDDLESEX NJ NJ0262 METUCHEN MIDDLESEX NJ NJ0263 HIGHLAND PARK MIDDLESEX NJ NJ0289 PISCATAWAY MIDDLESEX NJ NJ0348 NEW BRUNSWICK MIDDLESEX NJ NJ0364 SAYREVILLE MIDDLESEX NJ NJ0370 SOUTH AMBOY MIDDLESEX NJ t- NJ0371 MATAWAN MIDDLESEX NJ Cablevision Systems Corp. June 6, 2014 Page 5of12 Corumunitv Unit ID Community Name County State NJ0376 NORTH SRUNSWICK MIDDLESEX NJ NJ0377 MILLTOWN MIDDLESEX NJ NJ0398 OLD BRIDGE MIDDLESEX NJ NJ0400 ABERDEEN MIDDLESEX NJ NJ0069 ASBURY PARK MONMOUTH NJ NJ0161 OCEAN MONMOUTH NJ NJ02n AVON-BY-THE-SEA MONMOUTH NJ NJ0278 BELMAR MONMOUTH NJ NJ0279 BRADLEY BEACH MONMOUTH NJ NJ0280 BRIELLE MONMOUTH NJ NJ0281 MANASQUAN MONMOUTH NJ NJ0282 NEPTUNE CITY MONMOUTH NJ NJ0283 NEPTUNE MONMOUTH NJ NJ0284 SEA GIRT MONMOUTH NJ NJ0285 SPRING LAKE MONMOUTH NJ NJ0286 SOUTH BELMAR MONMOUTH NJ NJ0287 SPRING LAKE HEIGHTS MONMOUTH NJ NJ0288 WALL MONMOUTH NJ NJ0456 INTERLAKEN MONMOUTH NJ NJ0483 F.ARMINGDALE MONMOUTH NJ NJ0399 KEANSBURG MONMOUTH NJ NJ0401 UNION BEACH MONMOUTH NJ NJ0408 KEYPORT MONMOUTH NJ NJOS61 ALLENTOWN MONMOUTH NJ NJ0428 FREEHOto MONMOUTH NJ NJ0429 ENGLISHTOWN MONMOUTH NJ NJ0430 MANALAl'AN MONMOUTH NJ NJ0531 HOWELL MONMOUTH NJ NJ0556 COLTS NECK MONMOUTH NJ NJOSS:7 MARLBORO MONMOUTH NJ NJ0617 MILLSTONE MONMOUTH NJ NJ0618 UPPER FREEHOLD MONMOUTH NJ NJ0033 BUTLER MORRIS NJ NJ0171 KINNELON MORRIS NJ NJ0184 RIVERDALE MORRIS NJ NJ0185 LINCOLN PARK MORRIS NJ NJ0191 PEQUANNOCK MORRIS NJ NJ0407 MONTVILLE MORRIS NJ NJ0120 PARSIPPANY-TROY HILL MORRIS NJ NJ0121 MOUNTAIN LAKES MORRIS NJ NJ0123 MOUNT OLIVE MORRIS NJ NJ0125 MORRISTOWN MORRIS NJ - NJ0133 DOVER MORRIS NJ -NJ0134 MINE HILL MORRIS NJ Cablevision Systems Corp. June 6, 2014 Page 6of12 Communitv Unit ID Communitv Name County State NJ0135 ROCl Communitv Unit ID Community Name County State NJ0234 GREEN BROOK SOMERSET NJ NJ0235 SOUTH BOUND BROOK SOMERSET NJ NJ0236 WARREN SOMERSET NJ NJ0238 BOUND BROOK SOMERSET NJ NJ0290 MANVILLE SOMERSET NJ NJ0291 RARITAN SOMERSET NJ NJ0292 SOMERVILLE SOMERSET NJ NJ0330 BRIDGEWATER SOMERSET NJ NJ0485 WATCHUNG SOMERSET NJ NJ0486 BERNARDS SOMERSET NJ NJ0610 THE HILLS@ BEOMNSTR SOMERSET NJ NJ0190 MONTAGUE SUSSEX NJ NJ0628 SANDYSTON TOWNSHIP SUSSEX NJ NJ0137 STANHOPE SUSSEX NJ NJ0142 HOPATCONG SUSSEX NJ NJ0117 ELIZABETH UNION NJ NJ0027 ALLAMUCHY WARREN NJ NY1414 BRONX BRONX NY NY0213 DOVER DUTCHESS NY NV0271 BEACON DUTCHESS NY NY0272 FISHKILL DUTCHESS NY NY0273 FISHKILL DUTCHESS NY NY0274 HYDE PARK DUTCHESS NY NY0275 EAST FISHKILL DUTCHESS NV NY0278 WAPPINGERS FALLS DUTCHESS NY NY0308 WAPPINGER DUTCHESS NV NY0309 POUGHKEEPSIE DUTCHESS NY NY0375 LAGRANGE DUTCHESS NY NY0657 AMENIA DUTCHESS NY NV0658 WASHINGTON DUTCHESS NY NY1141 NORTHEAST DUTCHESS NV NY1142 MILLBROOK DUTCHESS NV NY1143 MILLERTON DUTCHESS NV NV1475 STANFORD DUTCH ESS NV NY1676 CLINTON DUTCHESS NY NY1997 MILAN DUTCHESS NY NY0453 NORTH HEMPSTEAD NASSAU NY NY0454 HEMPSTEAD NASSAU NV NY0489 OYSTER BAY NASSAU NV NY0611 GLEN COVE NASSAU NV NY0617 FARMINGDALE NASSAU NY NY0635 MASSAPEQUA PARK NASSAU NY NY0662 ROSLYN NASSAU NY NV0663 ROSLYN ESTATES NASSAU NY Cablevision Systems Corp. June 6, 2014 Page 8of12 Commtmitv Ueit ID Co1mnuaitv Name County ~tate NY0664 LAUREL HOLLOW NASSAU NY NY0665 BAYVILLE NASSAU NY NY0666 MINEOLA NASSAU NY NY0703 WESTBURY NASSAU NV NY0740 LONG BEACH NASSAU NV NY0741 VALLEY STREAM NASSAU NV NY0748 STEWART MANOR NASSAU NY NY0749 FREEPORT NASSAU NY NY0772 HEMP.STEAD NASSAU NY NY0774 FLORAL PARK NASSAU NY NY0790 NEW HYDE PARK NASSAU NY NV0791 SEA CLIFF NASSAU NY NY0816 ISLAND PARK NASSAU NV NV0834 MANORHAVEN NASSAU NY NY0835 BAXTER ESTATES ·NASSAU NY NY0839 BELLEROSE NASSAU NY NY0849 EAST ROCKAWAY NASSAU NY NY0855 PORT WASHINGTON NORT NASSAU NY NY0920 EAST WILLISTON NASSAU NV NY0924 CEDARHURST NASSAU NY NY0925 GARDEN CITY NASSAU NY NY0932 ATLANTIC BEACH NASSAU NY NY0933 HEWLETT HARBOR NASSAU NY NY0940 LYNBROOK NASSAU NV NY0953 ROCKVILLE CENTRE NASSAU NY NV1009 SOUTH FLORAL PARK NASSAU NY NY1011 WOODSBURGH NASSAU NY NY1032 EAST HILLS NASSAU NV NY1033 GREAT NECK NASSAU NY NY1034 GREAT NECK PLAZA NASSAU NY NY1035 GREAT NECK ESTATES NASSAU NY NY1036 KINGS POINT NASSAU NY NY1037 KENSINGTON NASSAU NY NY1038 RUSSELL GARDENS NASSAU NV NY1039 LAKE SUCCESS NASSAU NV NY1040 THOMASTON NASSAU NV NY1041 SADDLE ROCK NASSAU NY NY1042 PLANDOME NASSAU NY . NY1043 PLANDOME HEIGHTS NASSAU NY NY1044 PLANDOME PLAZA NASSAU NY NY1045 MUNSEY PARK NASSAU NY NY1046 FLOWER HILL NASSAU NV NV1047 NORTH HILLS NASSAU NY NY1053 LAWRENCE NASSAU NY Cablevision Systems Corp. June 6, 2014 Page 9of12 Communitv Unit m Comm11nitv Name County State NY1065 HEWLEITNECK NASSAU NY NY1096 OLD WESTBURY NASSAU NV NY1132 LATTINGTOWN NASSAU NY NY1133 MUTTONTOWN NASSAU NY NY1134 OYSTER BAY COVE NASSAU NY NV1135 UPPER BROOKVILLE NASSAU NY NY1145 COVE NECK NASSAU NY NY1146 MATINECOCK NASSAU NY NY1185 MILL NECK NASSAU NY NY1186 MALVERNE NASSAU NY NYl187 HEWLETT BAY PARK NASSAU NY NY1215 SANDS POINT NASSAU NY NY1308 OLD BROOKVILLE NASSAU NY NY1473 ROSLYN HARBOR --· NASSAU NY NY1474 BROOKVILLE NASSAU NY NY1551 CENTRE ISLAND NASSAU NY NY1461 UNIONVALE NASSAU NY N.Y0714 WILLISTON PARK NASSAU NY NY1413 BROOKLYN NEW YORK NY NY0906 TUXEDO ORANGE NY NY0939 TUXEDO PARK ORANGE NY NY0672 WARWICK ORANGE NY NY0673 GREENWOOD LAKE ORANGE NV NY0674 FLORIDA ORANGE NV NY0675 WARWICK ORANGE NY NY0752 CHESTER ORANGE NY NY0753 CHESTER . ORANGE NY NY1354 UNIONVILLE ORANGE NY NY1355 MINISINK ORANGE NY NY1694 GREENVILLE ORANGE NY NY0047 BLOOMING GROVE ORANGE NY NY0048 MONROE ORANGE NY NV0049 WOODBURY ORANGE NY NY0305 MONROE ORANGE NY NY0726 HARRIMAN . ORANGE NY NY1938 SOUTH BLOOMING GROVE ORANGE NY - NY1208 PHILIPSTOWN PUTNAM NY NY1116 COLDSPRING PUTNAM NY NY1209 NELSONVILLE PUTNAM NY NY1688 PHILIPSTOWN PUTNAM NY NY1897 TOWN OF KENT PUTNAM NY NY1083 PUTNAM VALLEY PUTNAM NY - . NV0286 HAVERSTRAW ROCKLAND NY NY0287 HAVERSTRAW ROCKLAND - - NY Cablevision Systems Cotp. June 6, 2014 Page 10of12 Community Unit ID Communitv Name County State NY0290 STONY POINT ROCKLAND NY NY0291 WEST HAVERSTRAW ROCKLAND NY NY0447 SPRING VALLEY ROCKLAND NY NY0448 RAMAPO ROCKLAND NV NY0449 •CLARKSTOWN ROCKLAND NY NY0794 ORANGETOWN ROCKLAND NV NY0842 SUFFERN ROCKLAND NV NY0869 UPPER NYACK ROCKLAND NV NY0870 SOUTH NYACK ROCKLAND NY NY0871 PIERMONT ROCKLAND NY NY0872 NYACK ROCKLAND NY NY0873 GRANDVIEW ROCKLAND NY NY0905 SLOATSBURG ROCKLAND NY NY0938 HILLBURN ROCKLAND NV NY0951 POMONA ROCKLAND NV NY1263 WESLEY HILLS ROCKLAND NY NY1424 RAMAPO ROCKLAND NY l\IY:.l.464 NEW HEMPSTEAD ROCKLAND NY NY1488 CHESTNUT RIDGE ROCKLAND NY NY1601 MONTEBELLO ROCKLAND NY NY1534 AIRMONT ROCKLAND NY NV1662 RAMAPO CORRIDOR ROCKLAND NY NY0052 SROOKHAVEN SUFFOLK NV NV0363 PATCHOGUE SUFFOLK NY NY0451 LAKE GROVE SUFFOLK NY NY0581 BELLPORT SUFFOLK NY NY0929 POQUOTT SUFFOLK NY NY1981 VILLAGE OF MASTIC BEACH SUFFOLK NY NY0237 BROOKHAVEN SUFFOLK NY NY0239 ISLIP SUFFOLK NY ' NY0242 SMITHTOWN SUFFOLK NY NY0667 VILLAGE OF BRANCH SUFFOLK NY NY0690 BRIGHTWATERS SUFFOLK NY NY0691 SHOREHAM SUFFOLK NY NY0713 PORT JEFFERSON SUFFOLK NY NY1403 BELLE TERRE SUFFOLK NY NY1429 NISSEQUOGUE SUFFOLK NY NY1506 HEAD OF THE HARBOR SUFFOLK NY NY1576 OLD FIELD SUFFOLK NY NY1689 ISLAND IA SUFFOLK NY NY0379 ISLIP SUFFOLK NY NY0391 AMITYVILLE SUFFOLK NY NY0392 HUNTINGTON SUFFOLK NY NY0399 BABYLON SUFFOl:K NY Cablevision Systems Corp. June 6, 2014 Page 11of12 Communitv Unit ID Communi!}'. Name County State NY0421 LINDENHURST SUFFOLK NY NY0423 BABYLON SUFFOLK NY NY0652 NORTHPORT SUFFOLK NY NY0653 HUNTINGTON BAY SUFFOLK NY NY1010 ASHAROKEN SUFFOLK NY NY1306 LLOYD HARBOR SUFFOLK NY NY0149 EAST HAMPTON SUFFOLK NY NY0150 EAST HAMPTON SUFFOLK NY NY0176 GREENPORT SUFFOLK NY NY0183 QUOGUE SUFFOLK NY NY0186 RIVERHEAD SUFFOLK NY NY0187 SAG HARBOR SUFFOLK NY NV0188 SOUTHOLD SUFFOLK NV NY0190 SOUTHAMPTON SUFFOLK NY NY0192 SOUTHAMPTON SUFFOLK NY NY0197 WESTHAMPTON BEACH SUFFOLK NY NY0238 DERING HARBOR SUFFOLK NY NY0240 NORTH HAVEN SUFFOLK NY NY0241 SHELTER ISLAND SUFFOLK NY NV1728 WEST HAMPTON DUNES SUFFOLK NY NY1819 SAGAPONACK SUFFOLK NY .NY0276 LLOYD ULSTER NY NY0306 MARLBOROUGH ULSTER NY NY0307 PLATTEKILL ULSTER NY NY1462 PINE PLAINS ULSTER NY NY1818 ESOPUS ULSTER NY NY0281 BUCHANAN WESTCHESTER NY NY0284 PEEKSKILL WESTCHESTER NY NY0731 MOUNT PLEASANT WESTCHESTER NY NV0732 NEWCASTLE WESTCHESTER NY NV0733 OSSINING WESTCHESTER NV NY0734 BRIARCLIFF MANOR WESTCHESTER NY NY0735 SLEEPY HOLLOW WESTCHESTER NY NY0736 OSSINING WESTCHESTER NY NY0737 PLEASANTVILLE WESTCHESTER NY NV0738 TARRYTOWN WESTCHESTER NY NVOnl CORTLANDT WESTCHESTER NV NY1086 CROTON-ON-HUDSON WESTCHESTER NV NY1423 BEDFORD WESTCHESTER NY NV0468 ELMSFORD WESTCHESTER NV NV0700 NEW ROCHELLE WESTCHESTER NY NY0701 SCARSDALE WESTCHESTER NV NV0739 EASTCHESTER WESTCHESTER NY NY0743 TUCKAHOE WESTCHESTER NV Cablevision Systems Corp. June 6, 2014 Page 12of 12· Community Unit ID Community Name County State NY0750 BRONXVILLE WESTCHESTER NY NY0792 DOBBS FERRY WESTCHESTER NY NY0793 ARDSLEY WESTCHESTER NY NY0803 PELHAM WESTCHESTER NY NY0804 PELHAM MANOR WESTCHESTER NY NY0805 WHITE PLAINS WESTCHESTER NY NY0814 RYE WESTCHESTER NY NY0815 GREENBURGH WESTCHESTER NY NY0851 IRVINGTON WESTCHESTER NY NY0868 HASTINGS-ON HUDSON WESTCHESTER NV NY0900 MAMARONECK WESTCHESTER NY NY0901 MAMARONECK WESTCHESTER NY NV0902 LARCHMONT WESTCHESTER NY NY0982 RYE BROOK WESTCHESTER NY NY1277 NORTH CASTLE WESTCHESTER NY NY0638 YONKERS WESTCHESTER NY NY1381 NORTH SALEM WESTCHESTER NV NY1382 LEWISBORO WESTCHESTER NY NY1489 POUND RIDGE WESlCHESTER NV . NV1092 PORT CHESTER WESTCHESTER NY NY1107 HARRISON WESTCHESTER NY NY0426 BEDFORD WESTCHESTER NY NY0427 MOUNT KISCO WESTCHESTER NY NY0942 YORKTOWN WESTCHESTER NY NY1056 . NORTH CASTLE WESTCHESTER NY NY1066 SOMERS WESTCHESTER NV PA1448 MATAMORAS PIKE PA PA1969 WESTFALL PIKE PA CERTIFICATE OF SERVICE I, Penny Evetts, hereby ce1tify that on this 9th day of September, 2014, I caused copies of the foregoing "Opposition of Time Warner Cable Inc. and Cablevision Systems Corporation to Application for Review of PMCM TV LLC" to be placed in the U.S. Postal Service, first class postage prepaid, or hand-delivered (as indicated below) addressed to the following persons: Commissioner Mignon Clyburn (by hand) Joyce Bernstein (by hand) Federal Communications Commission Video Division 445 12th Street, S.W. Media Bureau Washington, D.C. 20554 Federal Communications Commission 445 12th Street, S.W. Commissioner Michael O' Rielly (by hand) Washington, D.C. 20554 Federal Conununications Commission 45 12th Street, S.W. Donald J. Evans Washington, D.C. 20554 Fletcher, Heald & Hildreth, P.C. l3 00 N. 17th Street - 11th Floor Commissioner Ajit Pai (by band) Arlington, VA 22209 Federal Communications Commission Counsel for PMCMTV, LLC 445 12th Street, S.W. Washington, D.C. 20554 Michael D. Basile Robert J. Folliard, III Commissioner Jessica Rosenworcel (by hand) 1299 Pennsylvania Avenue, N.W. Federal Communications Commission Washington, D.C. 20004 445 12th Street, S.W. Counsel for Meredith Corporation Washington, D.C. 20554 Eve R. Pogoriler Chainnan Tom Wheeler (by hand) Covington & Burling LLP • I Federal Communications Commission 12011 Pennsylvama A venue NW 445 12th Street, S.W. Washington, D.C. 20004 Washington, D.C. 20554 Counsel for ION Media License Co, LLC Jonathan Sallet, General Counsel (by hand) Frederick W. Giroux Office of General Counsel Davis Wright Tremaine LLP Federal Communications Commission 1919 Pennsylvania Avenue, N.W. 445 12th Street, S.W. Suite 800 Washington, D.C. 20554 Washington, D.C. 20006-3401 Counsel for Comcast Barbara Kreisman, Chief (by hand) Video Division Anne Lucey Media Bureau CBS Corporation Federal Communications Commission 601 Pennsylvania Avenue, N.W. 445 12th Street, S.W. Suite 540 Washington, D.C. 20554 Washinsz.ton, D.C. 20004 AM 37238907.1 Bill LeBeau Holland and Knight 800 17th Street, N.W. Suite 1100 WashinRton D.C. 20006 AM 37238907.1