FCC Record, Volume 27, No. 7, Pages 5674 to 6652, May 23 - June 15, 2012 Page: 5,694
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3. On April 18, 2008, Fisher, through its Counsel, filed a letter with the Commission
regarding its own Contest, called the "Secret Listener Salute" that aired on Station KVI(AM) between
February 6, 2007, and March 30, 2007.1 The Licensee asserts that, as part of an internal year end audit in
2008, it discovered that a former employee may have taken actions to manipulate the outcome of the
Contest by placing the names of suspected friends and acquaintances on the list of names to be announced
on air, thus making them potential winners." Fisher indicates that winnings may have been shared
between the former employee and the winners.'2 Fisher states that it discovered this problem after the
employee left Fisher's employ, and that Fisher subsequently contacted the Seattle Police Department.'
On June 24, 2008, the Bureau sent a letter to Fisher regarding the Contest,'4 and Fisher responded on July
30, 2008.15 The Bureau subsequently sent a second letter to Fisher on May 7, 2010,16 to which Fisher
responded on June 3, 2010."7 Fisher contends that it was unaware of the former employee's actions until
after she had left the Station's employ, that it was an unwitting victim in this situation, and that it alerted
the Commission and law enforcement once it determined what had happened.'s Fisher contends that the
actions of the former employee violated the Station's Code of Conduct and Conflict of Interest Policies
that were in place at the time the alleged violations occurred.'9 Fisher claims that it will create added
oversight to all future contests and monitor their implementation to safeguard against any future
manipulations by any party.20 The terms of this Consent Decree reflect the Bureau's consideration of the
Licensee's self-disclosure of this matter and the Licensee's prior history of compliance with Commission
1o See Letter from Clifford M. Harrington, Esq.. Pillsbury Winthrop Shaw Pittman LLP, Counsel for Fisher
Broadcasting - Seattle Radio, L.L.C. (Counsel) to Hillary S. DeNigro, Chief, Investigations and Hearings Division,
FCC Enforcement Bureau (April 18, 2008) (on file in EB-08-IH-1203) (Fisher April 18 Letter).
" Id. at 1.
14 See Letter from Kenneth M. Scheibel, Jr., Assistant Chief, Investigations and Hearings Division, FCC
Enforcement Bureau, to Counsel (June 24, 2008) (on file in EB-08-IH-1203).
i See Letter from Counsel to Marlene Dortch, Secretary, Federal Communications Commission (July 30, 2008) (on
file in EB-08-IH-1203) (Fisher July 30 Letter).
1' See Letter from Anjali K. Singh, Acting Assistant Chief, Investigations and Hearings Division, FCC Enforcement
Bureau, to Counsel (May 7, 2010) (on file in EB-08-Ilt-1203).
17 See Letter from Counsel to Marlene Dortch, Secretary, Federal Communications Commission (June 3, 2010) (on
file in EB-08-IH-1203).
18 See Fisher April 18 Letter at 1. According to court records, Ms. Ryan Keeley, Fisher's former Promotions
Coordinator at the Station, was convicted by a King County, Washington, court and ordered to pay $14,000 in
restitution after pleading guilty to second-degree theft for her role in the Contest. Washington v. Keeley, et al., No.
10C-00364-5 SEA (King Cnty. Sup. Ct. 2010). Keeley pled guilty to violating RCW 9A.56.040(1)(a) and
9A.56.020(1)(b) of the Revised Washington criminal code. See also Jennifer Sullivan, KVI Ex-employee Sentenced
for Rigging Radio Contest, Seattle Times online edition, July 30, 2010,
http: 'scattlctimes.nwsource.conl htmllocalne s/201 2494429 rignedcontest31 m.html (last visited Sept. 16, 2011).
'* See Fisher July 30 Letter at 16-17.
20 See Fisher April 18 Letter at 1-2.
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United States. Federal Communications Commission. FCC Record, Volume 27, No. 7, Pages 5674 to 6652, May 23 - June 15, 2012, book, June 2012; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc111171/m1/37/: accessed April 27, 2017), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.