Federal Communications Commission DA 11-1272
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
HK Media, Inc.
Licensee of Station KFOX
Torrance, California
Facility ID # 87242
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File No. EB-10-LA-0238
NAL/Acct. No. 201132900005
FRN 0020919791
NOTICE OF APPARENT LIABILITY FOR FORFEITURE
Adopted: July 27, 2011 Released: July 29, 2011
By the District Director, Los Angeles Office, Western Region, Enforcement Bureau:
I. INTRODUCTION
1. In this Notice of Apparent Liability for Forfeiture (“NAL”), we find that HK Media, Inc. 
(“HK Media”), licensee of Station KFOX, in Torrance, California, apparently willfully and repeatedly 
violated section 73.3526 of the Commission’s rules (“Rules”)1 by failing to maintain and make available for 
inspection a local public inspection file at the Station KFOX main studio.  We conclude that HK Media is 
apparently liable for a forfeiture in the amount of ten thousand dollars ($10,000).
II. BACKGROUND
2. On September 22, 2010, an agent from the Enforcement Bureau’s Los Angeles Office 
(“Los Angeles Office”) conducted an inspection at the main studio of Station KFOX in Los Angeles, 
California.  The agent requested to review the station’s public inspection file, however, the station’s staff, 
including the Operations Manager and contract engineer, could not locate the public inspection file. 
3. In response to a Letter of Inquiry issued by the Los Angeles Office, the President of HK 
Media stated that the Station KFOX public file materials were destroyed due to water damage at the 
station’s studio location in May 2010.2 HK Media acknowledged that a complete public inspection file 
was not recreated until the week after the Los Angeles agent’s inspection in September 2010.3  
III. DISCUSSION
4. Section 503(b) of the Communications Act of 1934, as amended (“Act”),4 provides that any 
  
1 47 C.F.R. § 73.3526.
2 See Letter of Inquiry from Nader Haghighat, District Director, Los Angeles Office, Western Region, Enforcement 
Bureau, to HK Media, Inc., dated March 8, 2011 (“LOI”); Response from Grant Chang, President, HK Media, Inc., 
to Nader Haghighat, District Director, Los Angeles Office, Western Region, Enforcement Bureau, dated April 8, 
2011 (“LOI Response”).
3 LOI Response at 3.
4 47 U.S.C. § 503(b).
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person who willfully or repeatedly fails to comply substantially with the terms and conditions of any license, 
or willfully or repeatedly fails to comply with any of the provisions of the Act or of any rule, regulation or 
order issued by the Commission thereunder, shall be liable for a forfeiture penalty.  Section 312(f)(1) of the 
Act defines willful as the “conscious and deliberate commission or omission of [any] act, irrespective of any 
intent to violate” the law.5 The legislative history to section 312(f)(1) of the Act clarifies that this definition 
of willful applies to both section 312 and 503(b) of the Act6 and the Commission has so interpreted the term 
in the section 503(b) context.7 The Commission may also assess a forfeiture for violations that are merely 
repeated, and not willful.8 The term “repeated” means the commission or omission of such act more than 
once or for more than one day.9
5. Section 73.3526(a)(2) of the Rules requires that every licensee of an AM or FM station 
shall maintain a public inspection file containing the material, relating to that station, described in Section 
73.3526(e) of the Rules.10 Section 73.3526(b)(1) of the Rules requires that the public inspection file shall 
be maintained at the station’s main studio.11 Section 73.3526(c)(1) of the Rules specifies that the file 
shall be available for public inspection at any time during regular business hours.12
6. On September 22, 2010, a Los Angeles agent attempted to review the Station KFOX public 
inspection file but there was no file available for review at the main studio location.  In its LOI Response, 
HK Media acknowledged that the Station KFOX public inspection had been destroyed in May 2010 and 
was not recreated until after the inspection by the Los Angeles agent.  Consequently, the Station KFOX 
public inspection file was unavailable to the public for a period of four months.   Accordingly, based on the 
evidence before us, we conclude that HK Media apparently willfully and repeatedly violated section 73.3526
of the Rules by failing to maintain and make available the Station KFOX public inspection file at the 
station’s main studio. 
7. Pursuant to the Commission’s Forfeiture Policy Statement and section 1.80 of the Rules, the 
base forfeiture amount for violation of the public file rule is $10,000.13 In assessing the monetary 
  
5 47 U.S.C. § 312(f)(1).
6 H.R. Rep. No. 97-765, 97th Cong. 2d Sess. 51 (1982) (“This provision [inserted in section 312] defines the terms 
‘willful’ and ‘repeated’ for purposes of section 312, and for any other relevant section of the act (e.g., section 
503)….   As defined … ‘willful’ means that the licensee knew that he was doing the act in question, regardless of 
whether there was an intent to violate the law. ‘Repeated’ means more than once, or where the act is continuous, for 
more than one day. Whether an act is considered to be ‘continuous’ would depend upon the circumstances in each 
case. The definitions are intended primarily to clarify the language in sections 312 and 503, and are consistent with 
the Commission’s application of those terms …”).
7 See, e.g., Application for Review of Southern California Broadcasting Co., Memorandum Opinion and Order, 6 
FCC Rcd 4387, 4388 (1991) (“Southern California Broadcasting Co.”).
8 See, e.g., Callais Cablevision, Inc., Notice of Apparent Liability for Monetary Forfeiture, 16 FCC Rcd 1359, 1362 
¶ 10 (2001) (“Callais Cablevision, Inc.”) (proposing a forfeiture for, inter alia, a cable television operator’s repeated 
signal leakage). 
9 Section 312(f)(2) of the Act, 47 U.S.C. § 312(f)(2), which also applies to violations for which forfeitures are 
assessed under section 503(b) of the Act, provides that “[t]he term 'repeated', when used with reference to the 
commission or omission of any act, means the commission or omission of such act more than once or, if such 
commission or omission is continuous, for more than one day.” 
10 47 C.F.R. § 73.3526(a)(2). 
11 47 C.F.R. § 73.3526(b)(1).
12 47 C.F.R. § 73.3526(c)(1).
13 12 The Commission’s Forfeiture Policy Statement and Amendment of Section 1.80 of the Rules to Incorporate the 
Forfeiture Guidelines, Report and Order, 12 FCC Rcd 17087 (1997) (“Forfeiture Policy Statement”), recon. denied, 
15 FCC Rcd 303 (1999); 47 C.F.R. § 1.80.
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forfeiture amount, we must also take into account the statutory factors set forth in section 503(b)(2)(E) of 
the Act, which include the nature, circumstances, extent, and gravity of the violations, and with respect to 
the violator, the degree of culpability, and history of prior offenses, ability to pay, and other such matters 
as justice may require.14 Applying the Forfeiture Policy Statement, section 1.80 of the Rules, and the 
statutory factors to the instant case, we conclude that HK Media is apparently liable for a $10,000 
forfeiture.  
IV. ORDERING CLAUSES
8. Accordingly, IT IS ORDERED that, pursuant to section 503(b) of the Communications 
Act of 1934, as amended, and sections 0.111, 0.204, 0.311, 0.314 and 1.80 of the Commission's Rules, HK 
Media, Inc. is hereby NOTIFIED of this APPARENT LIABILITY FOR A FORFEITURE in the 
amount of ten thousand dollars ($10,000) for violations of section 73.3526 of the Rules.15
9. IT IS FURTHER ORDERED that, pursuant to section 1.80 of the Commission's Rules 
within thirty days of the release date of this Notice of Apparent Liability for Forfeiture, HK Media, Inc. 
SHALL PAY the full amount of the proposed forfeiture or SHALL FILE a written statement seeking 
reduction or cancellation of the proposed forfeiture.
10. Payment of the forfeiture must be made by credit card, check or similar instrument, 
payable to the order of the Federal Communications Commission.  The payment must include the 
Account Number and FRN Number referenced above.  Payment by check or money order may be mailed 
to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-9000.  Payment by 
overnight mail may be sent to U.S. Bank – Government Lockbox #979088, SL-MO-C2-GL, 1005 
Convention Plaza, St. Louis, MO 63101.  Payment by wire transfer may be made to ABA Number 
021030004, receiving bank TREAS/NYC, and account number 27000001.  For payment by credit card, 
an FCC Form 159 (Remittance Advice) must be submitted. When completing the FCC Form 159, enter 
the NAL/Account number in block number 23A (call sign/other ID), and enter the letters “FORF” in 
block number 24A (payment type code).  Requests for full payment under an installment plan should be 
sent to: Chief Financial Officer -- Financial Operations, 445 12th Street, S.W., Room 1-A625, 
Washington, D.C. 20554.8  If you have questions, please contact the Financial Operations Group Help 
Desk at 1-877-480-3201 or Email: ARINQUIRIES@fcc.gov.  If payment is made, HK Media, Inc. will 
send electronic notification on the date said payment is made to WR-Response@fcc.gov.
11. The written statement seeking reduction or cancellation of the proposed forfeiture, if any, 
must include a detailed factual statement supported by appropriate documentation and affidavits pursuant 
to sections 1.80(f)(3) and 1.16 of the Rules.  Mail the written statement to Federal Communications 
Commission, Enforcement Bureau, Western Region, Los Angeles Office, 18000 Studebaker Rd., Suite # 
660, Los Angeles, CA  90703 and include the NAL/Acct. No. referenced in the caption.  HK Media, Inc. 
shall also email the written response to WR-Response@fcc.gov.  
12. The Commission will not consider reducing or canceling a forfeiture in response to a claim 
of inability to pay unless the petitioner submits: (1) federal tax returns for the most recent three-year period; 
(2) financial statements prepared according to generally accepted accounting practices (“GAAP”); or (3) 
some other reliable and objective documentation that accurately reflects the petitioner’s current financial 
status.  Any claim of inability to pay must specifically identify the basis for the claim by reference to the 
financial documentation submitted.  
  
14 47 U.S.C. § 503(b)(2)(E).
15 47 U.S.C. § 503(b), 47 C.F.R. §§ 0.111, 0.204, 0.311, 0.314, 1.80, 73.3526.
8 See 47 C.F.R. § 1.1914.
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13. IT IS FURTHER ORDERED that a copy of this Notice of Apparent Liability for 
Forfeiture shall be sent by both Certified Mail, Return Receipt Requested, and regular mail, to HK Media, 
Inc., 4525 Wilshire Blvd., Los Angeles, California, 90010.
FEDERAL COMMUNICATIONS COMMISSION
Nader Haghighat
District Director 
Los Angeles Office
Western Region
Enforcement Bureau