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URL 37: FCC Commissioner Bill Ray’s Letter to Me (July 15, 1971)

URL 37: FCC Commissioner Bill Ray’s Letter to Me (July 15, 1971) (In Chapter 39, page 183) (430 words) (43,430 cum words)

Dear Dr. Hendon: This will acknowledge your letters of June 28 and 30, 1971, with further reference to stations KLAS-TV, KORK-TV, and KSHO-TV.

Concerning your statements in your letter of June 30 regarding the insertion of local commercials during network programming by station KORK-TV during the week of June 27, we are making inquiry of the licensee of the station in this respect.

With further reference to your allegations that the three stations referred to above have engaged in double-billing, it should be pointed out that you have furnished no evidence of such practices on the part of any of these three stations. In your letter of June 28, you indicate your understanding of the need for the study of various types of records to establish whether our double-billing rules may have been violated. The enclosure with your letter appears to be a copy of a projected schedule or film director’s copy of the log for Station KLAS-TV for March 31. It is not a copy of the official log for the date showing, with appropriate notations and signatures, the actual program operation for March 31 as broadcast. Inquiries involving double-billing usually require extensive and detailed study of official logs for periods of many weeks or months of operation in conjunction with inspection of such material as contracts, affidavits, bills, rate cards, network TWX messages ordering a station commercially or permitting or ordering deletion of commercial matter, network billing analysis sheets, station books of account, etc. The tentative log or projected schedule you have sent to us simply indicates that certain unspecified network matter may have been scheduled for deletion by Station KLAS-TV on March 31 and is accompanied by no evidence that such deletions were not in accord with network contracts, or any other evidence of possible violation of any law or regulation.

The Commission has a limited staff and can make investigations only on a basis of strict priority and upon receipt of evidence of possible violation of statute or of its rules or policies. We must rely upon public cooperation in this regard. You, for example, have supplied information regarding insertion of commercial material during network programs, which information formed the basis, in part, for our current inquiry of Las Vegas stations. If you or your informant or other persons can furnish copies of material of the kind referred to above respecting double-billing, we will give the matter further consideration. At the present time, however, we have no indication that any of the stations to which you refer has violated our double-billing rules.

Thank you for writing.

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