A recently issued Notice of Apparent Liability (NAL), accompanies by a sharp dissent from Commissioner Pai, leaves no doubt that the Commission continues to find new creative and novel ways to bring alleged infractions within the applicable one-year statute of limitations.  We have commented on the Commission’s to push the envelope in its interpretation of when the statute begins to run on several prior occasions.  The present NAL in question was issued December 11, 2013, against Intelsat License LLC stemming from a license amendment submitted on March 2, 2010, more than forty-three months prior to the NAL.
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