Attachment 2019_03_29_15_24_33.

2019_03_29_15_24_33.

LETTER submitted by Grant of Request for Extension of Time to Respond

Grant of Request for Extension of Time to Respond

2019-03-14

This document pretains to 325-NEW-20180614-00001 for New Application on a Permit to Foreign Broadcast filing.

IBFS_325NEW2018061400001_1641118

                          Federal Communications Commission
                                Washington, D.C. 20554

                                          March 14, 2019

Paige K. fronabarger, Esq.
Wilkinson Barker Knauer LLP
800 M Street, N.W.
Suite 800N
Washington, D.C. 20036


   Re: GLR Southern California, LLC and its parent company H&H Group USA LLC                 Request
for Extension of Time.
        IBFS File No. 325-NEW-20 180614-00001

Dear Ms. Fronabarger

         This letter responds to your March 1, 2019 request for a three-week extension of time to
respond to the Information Request (“Information Request”) issued to GLR Southern California,
LLC and its parent company H&H Group USA LLC (collectively Applicants) on february 15,
2019. For the reasons discussed below we grant a four-day extension of time, extending the
deadline for response to the Information Request from March 18, 2019 to March 22, 2019 to
reflect the delay in mailing of the Certified mail until February 19, 2019, but otherwise deny the
Applicants’ request, including the request to narrow the scope of the questions in the Information
Request.

         The Commission does not routinely grant extensions of time.’ The public interest,
however, would be served by granting a four-day limited extension to reflect the delay in mailing
the Information Request so that we can receive a full record in the proceeding.2 We note that we
allocated the initial response time by carefully balancing the public interest needs after taking into
account the complexity of the case and any coordination that may be necessary for privileged and
confidential information as well as any needed translation of non-English documents.
Accordingly, we believe that this limited extension would allow the Applicants to respond fully
and adequately without narrowing the request. We note that our decision to extend the time for
the Applicants to respond does not prejudice any other action that the Commission may take on
the Applicants’ other pending requests3 as we take no action on those requests in this letter.4

       With respect to the request to clarify the scope of the Information Request, first, please
produce all information and documents as requested and included in each question. If some

‘47 C.f.R. § 1.46.
2
 47 U.S.C. § 309(a).
 See IBfS file No. 325-NEW-201 80614-00001 for the underlying Section 325(c) permit application and
IBFS File No. 325-STA-20180710-00002 for the pending request for extension of GLR’s Permit for
Special Temporary Authority to Deliver Programs to Foreign Broadcast Station.
447 C.f.R. 1.1.
           §


relevant documents are retained and not produced, please indicate the relevant question and the
reasons why the Applicants believe the documents responsive to that question should not be
produced (e.g., eliminating exact duplicate documents from the production). Second, with
respect to questions 24(a) and 24(b), the Information Request includes, and we expect the
Applicants to provide, any information pertaining to consideration paid to GLR, H&H, or
Phoenix and each of their respective affiliates or other third parties as specified in the questions
(note that this should not be construed as a modification of the Information Request).
Additionally, a list of station advertisers and program suppliers would be a useful document
alongside other documents responsive to questions 24(a) and 24(b). Those documents written in
a language other than English must be translated into English; automated or machine translations
are permitted; however, the Commission retains the right to require a non-machine translation.
Submit the foreign language document, with the English translation attached thereto.


                                                  Sincerely,


                                                  tf
                                                  Thomas Sullivan
                                                  Chief
                                                  International Bureau

cc:       David D. Oxenford
          Christopher D. Bair
          Wilkinson Barker Knauer LLP
          800 M Street, NW
          Suite 800N
          Washington, D.C. 20036

          GLR Southern California, LLC
          6 the Drawbridge
          Woodbury, NY 11797

         GLR Services, Inc.
         2100 Coral Way, Suite 200
         Miami, FL 33145

         H&H Group USA, LLC
         28th Floor, 40 Wall Street
         New York, NY 10005

         Reid Avett
         Duane Morris, LLP
         505 9th Street, N.W., Suite 1000
         Washington, D.C. 20004-2 166

         James L. Winston
         Rubin, Winston, Diercks, Harris & Cooke, LLP
         1201 Connecticut Avenue, N.W., Suite 200
         Washington, D.C. 20036

                                                  2



Document Created: 2019-05-31 06:05:57
Document Modified: 2019-05-31 06:05:57

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