Investigate Sinclair Broadcast Group and Cunningham Broadcasting Corporation sign now

Dear sirs,

Based on an overwhelming amount of corporate evidence, the Sinclair Broadcast Group is operating illegal duopolies in six television markets by way of a shell corporation, Cunningham Broadcasting Corporation. All six of Cunningham's stations--WNUV in Baltimore, Maryland; WTTE in Columbus, Ohio; WMYA-TV in Anderson, South Carolina; WRGT in Dayton, Ohio; WVAH-TV in Charleston, West Virginia; and WTAT-TV in Charleston, South Carolina--are located in the same markets as Sinclair stations, and have local marketing agreements with Sinclair. Nearly all of Cunningham's stock is controlled by trusts in the name of the Smith family, owners and founders of Sinclair. Since Cunningham represents itself as a separate entity from Sinclair, we believe that Sinclair and Cunningham are blatantly misleading the FCC.

However, there is evidence that Sinclair and Cunningham have flouted the FCC's rules regarding duopolies even further. Cunningham's six stations are located in markets where Sinclair cannot legally operate duopolies. In the case of WMYA, a purchase by Sinclair would leave only seven unique station owners in the Greenville-Spartanburg-Asheville market. Your regulations require that a market must have eight unique station owners once a duopoly is formed. In the case of WVAH, Sinclair cannot create a duopoly with WCHS-TV because your regulations do not allow common ownership of two of the four highest-rated stations in a market. In the case of WMYA, a Sinclair purchase would leave only seven unique owners in the GreenIn the other four cases, a Sinclair duopoly would not be permitted because it would not only involve two of the four highest-rated stations in a market, but the four markets do not have enough full-power stations to permit any duopolies at all.

Since Cunningham holds itself out as a separate company from Sinclair, we believe that based on this evidence, Sinclair and Cunningham have not displayed full candor before the FCC. Past precedent indicates that this is grounds for both parties to be held as unfit to be broadcast licensees. We, the undersigned, urge you to undertake a full investigation of Sinclair and Cunningham and take all corrective measures necessary, up to and including stripping their licenses.

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Jasmine LambertBy:
MusicIn:
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Federal Communications Commission

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