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                                Before the
                      Federal Communications Commission
                          Washington, D.C. 20554

In re Applications of               )
                                     )
                                   MERCURY PCS II, LLC )         File No.  00114-CW-L-97 et al.
                                     )
For Authority to Construct and Operate       )
Broadband Personal Communications Services        )
Systems on the D, E, and F Frequency Blocks      )
                                     

                  MEMORANDUM OPINION AND ORDER


     Adopted:  May 25, 2000             Released:  June 2, 2000

By the Commission:

                              TABLE OF CONTENTS
                                                                  Paragraph

I.  INTRODUCTION                                .1

II.  BACKGROUND                                                            

     A.  WTB Order on Reconsideration                             2
     B.  OGC Letter Decision on Reconsideration                      9               

III.  DISCUSSION                                                           

           A.  Bid Signaling                               .13             
                                                              
           B.  Misrepresentation and Lack of Candor                     ..14              
                                                              
           C.  Ex Parte Communications                          .22

IV.  CONCLUSION                                                       27
                                                                           

V.  ORDERING CLAUSES                                                  28


                             I.  INTRODUCTION

1.     This Memorandum Opinion and Order resolves two applications for review filed by High
Plains Wireless, L.P. (High Plains).  High Plains' first application for review concerns the WTB Order on
Reconsideration released by the Wireless Telecommunications Bureau (WTB) on November 5, 1997,
which unconditionally granted nine applications for broadband Personal Communications Services (PCS)
D and F block licenses filed by Mercury PCS II, LLC (Mercury), and removed conditions from twenty-
three other broadband PCS E and F block licenses previously granted to Mercury.  High Plains' second
application for review concerns the OGC Letter Decision on Reconsideration issued by the Office of
General Counsel (OGC) on April 6, 1998, which rejected High Plains' allegations that Mercury violated
our Ex Parte rules.  We have consolidated the two proceedings, and for the reasons that follow, we deny
High Plains' applications for review and affirm the WTB Order on Reconsideration and the OGC Letter
Decision on Reconsideration.

                               II.  BACKGROUND

     A.  WTB Order on Reconsideration

2.     The Commission conducted an auction of PCS licenses in the D, E, and F blocks from August
26, 1996 to January 14, 1997.  During the course of the auction, High Plains filed an emergency motion to
disqualify Mercury, alleging that Mercury had violated the Commission's auctions anti-collusion rule by
communicating its bidding strategy to other bidders, including High Plains, while bidding on the F block
licenses for Amarillo, Texas (BTA 013) and Lubbock, Texas (BTA 264).  Specifically, High Plains
claimed that Mercury incorporated the BTA number for the Lubbock license into the last three digits of
some of its bids for the Amarillo license, and the BTA number for the Amarillo license into the last three
digits of some of its bids for the Lubbock license.  According to High Plains, Mercury's use of these
"trailing numbers" was intended to signal High Plains that if it did not stop bidding for the Lubbock license,
then Mercury would retaliate by outbidding High Plains for the Amarillo license.  High Plains alleged that
after it stopped bidding for the Lubbock license, Mercury stopped bidding for the Amarillo license.  In
response to High Plains' emergency motion, Mercury claimed that it did not violate any Commission rules
and that the use of trailing numbers was common among other bidders in the D, E, and F block auctions. 
At the end of the auction, High Plains was the high bidder for the Amarillo F block license, while Mercury
was the high bidder for the Lubbock F block license. 

3.     Based on High Plains' allegations and Mercury's response, WTB launched a general
investigation into bid signaling in the D, E, and F block auctions.  WTB also forwarded High Plains'
emergency motion for disqualification to the Department of Justice (DOJ), which undertook its own civil
investigation into bid signaling in the D, E, and F block auctions, as well as other Commission auctions.
On March 21, 1997, High Plains filed a petition to deny all of Mercury's applications, reasserting its earlier
allegations of bid signaling.  In opposition, Mercury again denied that its use of trailing numbers violated
the anti-collusion rule.

4.     On August 21, 1997, WTB released an order conditionally granting twenty-three of Mercury's
licenses and deferring action on the remaining nine.  WTB granted the twenty-three licenses because it
found no evidence of bid signaling in those markets.  However, it conditioned the licenses on the outcome
of its continuing investigation into bid signaling.  WTB deferred action on the other nine licenses because
it found that bid signaling had occurred in those markets and concluded that further investigation was
warranted.  High Plains and Mercury both sought reconsideration of WTB's Partial Grant Order.  High
Plains argued that WTB prematurely granted the twenty-three Mercury licenses because WTB's ongoing
investigation could find that Mercury's behavior in the nine remaining markets was sufficiently egregious to
render Mercury unfit to hold any licenses.  In contrast, Mercury claimed that further investigation was
unnecessary and the deferral of its nine applications was unjustified because its conduct did not violate the
anti-collusion rule.

5.     On September 10, 1997, WTB's Enforcement and Consumer Information Division
(Enforcement) issued a letter of inquiry asking Mercury to answer a series of questions regarding its
bidding activities in the D, E, and F block auctions.  In response, Mercury admitted using trailing
numbers in its bids, but claimed that such activity was not a communication of bidding strategy and did not
violate Commission rules.  On October 28, 1997, the Commission released a Notice of Apparent Liability
for Forfeiture, which concluded the investigation into bid signaling by Mercury in the D, E, and F block
auction.  The Commission found that Mercury's use of "reflexive bid signaling" violated the anti-collusion
rule, and assessed Mercury a forfeiture in the amount of $650,000.00.  High Plains and Mercury each
sought reconsideration of the NALF.  High Plains argued that the forfeiture amount was insufficient and
failed to account for all of Mercury's reflexive bid signals during the auction.  In contrast, Mercury
argued that its conduct did not violate the anti-collusion rule and that the forfeiture amount was excessive. 


6.     On November 5, 1997, WTB issued the WTB Order on Reconsideration, removing the
conditions on Mercury's previously granted twenty-three licenses and unconditionally granting the nine
remaining licenses.  WTB concluded that, notwithstanding the NALF,  Mercury was qualified to be a
Commission licensee because Mercury believed that the use of trailing numbers was permissible under our
rules, admitted using trailing numbers, and did not intend to mislead or deceive the Commission or other
parties concerning its bidding conduct.

7.     High Plains filed an application for review of the WTB Order on Reconsideration on
December 5, 1997.  High Plains argues that when WTB granted Mercury's licenses it failed to fully
consider Mercury's: (1) bid signaling in the D, E, and F block auctions, (2) alleged misrepresentations and
lack of candor in responding to WTB's bid signaling investigation, and (3) alleged ex parte violations. 
Mercury filed an opposition to the application for review on December 22, 1997, claiming that High Plains'
arguments lacked merit.  
8.     While High Plains' application for review was pending, we rescinded the NALF against
Mercury on August 28, 1998.  In the NALF Reconsideration, we affirmed the Commission's earlier
conclusion in the NALF that Mercury's use of trailing numbers was prohibited under the anti-collusion
rule.  However, we concluded that Mercury did not have adequate notice that its conduct was improper,
and therefore, that Mercury should not be subject to a monetary forfeiture.  We cautioned, however, that
the use of trailing numbers for reflexive bid signaling is prohibited by the anti-collusion rule and will not be
tolerated in future auctions.

          B.  OGC Letter Decision on Reconsideration

9.     On August 14, 1997, High Plains alleged that an improper ex parte presentation concerning
Mercury was made to the Commission.  According to High Plains, Mercury solicited letters to be sent on
its behalf from a number of Congressional offices, and these letters addressed the merits of the applications
in violation of the Commission's ex parte rules.  High Plains further alleged that a Member of Congress or
Congressional staff member requested and received assurances from a Commission staff member that
Mercury's applications would be acted on by a certain date.  On October 24, 1997, OGC's Administrative
Law Division found that the communications between Commission staff and Congressional offices were
status inquiries that did not address the merits of the licensing proceeding.  Accordingly, the
Administrative Law Division concluded that there was no violation of our ex parte rules.
10.    On November 24, 1997, High Plains petitioned for reconsideration of the OGC Letter
Decision.  High Plains accused Mercury of orchestrating a campaign to influence the licensing process
through improper pressure from Congress.  High Plains noted that the Chairman's Office received letters
from twenty-seven Congressional offices addressing the status of Mercury's applications before the Partial
Grant Order was released, and another nine letters before the NALF and WTB Order on Reconsideration
were released.  High Plains asserted that Mercury prompted these Congressional inquiries by having a
consultant write to various Senators and Representatives in an effort to have them exert pressure on the
Commission to grant Mercury's applications.
11.    On April 6, 1998, OGC issued the OGC Letter Decision on Reconsideration, denying High
Plains' petition for reconsideration of the Administrative Law Division's Letter Decision.  OGC
concluded that the Congressional letters did not taint the decision-making process and that sanctions against
Mercury were unwarranted.  OGC also found that although service of the Congressional letters on High
Plains was not always timely, such a transgression of the ex parte rules was minor and did not call for
sanctions.
12.    On May 6, 1998, High Plains filed an application for review of the OGC Letter Decision on
Reconsideration, claiming that OGC failed to recognize the seriousness of Mercury's ex parte violations
and impose appropriate sanctions.  High Plains also filed a motion to consolidate its application for
review of the OGC Letter Decision on Reconsideration with its application for review of the WTB Order
on Reconsideration.  Because the two applications for review raise issues arising out of the same facts,
we will consider them together.  We will first address the bid signaling, misrepresentation, and lack of
candor arguments raised in High Plains' application for review of WTB's Order on Reconsideration, and
then we will address the ex parte arguments, which are common to both of High Plains' applications for
review.
          
                             III.  DISCUSSION

     A.  Bid Signaling

13.    High Plains argues that the WTB Order on Reconsideration "fails to consider the full scope
and impact of Mercury's illicit use of reflexive trailing numbers."  However, rather than alleging any
specific errors by the Bureau, High Plains focuses its argument on the NALF and asserts that the "relatively
nominal" forfeiture of $650,000 is insufficient in light of the number of reflexive bids placed by Mercury. 
We have previously addressed this issue fully in the NALF Reconsideration.  In light of our conclusion that
the NALF should be rescinded, we find no merit in High Plains' argument that WTB failed to consider the
full extent of Mercury's bid signaling when it granted Mercury's license applications.  

          B.  Misrepresentation and Lack of Candor

14.    High Plains cites several instances where Mercury allegedly misrepresented facts or lacked
candor in responding to WTB's Letter of Inquiry.  High Plains contends that these alleged
misrepresentations and lack of candor should disqualify Mercury from becoming a Commission licensee.
We will address each of High Plains' allegations in turn.

15.    First, High Plains claims that Mercury lacked candor in not admitting its use of trailing
numbers until after High Plains discovered Mercury's conduct and reported it to the Commission.  We
disagree.  As we explained in the NALF Reconsideration, Mercury did not have adequate notice that its use
of trailing numbers was prohibited by the anti-collusion rule.  Without adequate notice that its conduct
was prohibited, Mercury had no reason to report its use of trailing numbers to the Commission prior to the
Commission's inquiry.
16.    High Plains also alleges that Mercury lacked candor in responding to several specific questions
in WTB's Letter of Inquiry.  Question Four asked Mercury inter alia, to describe the purpose of its
trailing numbers.  High Plains alleges that Mercury's responses that the trailing numbers were meant to
"bluff and confuse" is inconsistent with Federal Court testimony by Mercury representative Jerry Sullivan,
Jr.  However, in response to Question Four of the Letter of Inquiry, Mercury stated: 
          Mercury utilized the final three digits of its bids to: (a) gain separation from other bidders
     above and beyond minimum bid increments; (b) to avoid the so-called "fat-finger" bid
     problem; and (c) to misdirect, bluff, threaten, and posture in relation to other bidders.[]

We find no inconsistency between Mercury's response to Question Four and Sullivan's statement. 
Accordingly, we reject High Plains' claim that Mercury lacked candor in responding to this question.

17.    Next, High Plains claims that Mercury omitted materials from its response to Question Five of
the Letter of Inquiry.  Question Five asked Mercury, inter alia, to produce all documents memorializing,
referring to or relating to its strategic plan and/or bidding strategy.  High Plains alleges that Mercury
failed to produce certain bidding diaries that were purportedly responsive to the request.  In opposition,
Mercury maintains that the bidding diaries do not contain material responsive to Question Five of the Letter
of Inquiry.  Nonetheless, pursuant to a request from the Commercial Wireless Division, Mercury
submitted copies of its bidding diaries on October 2, 1998.  In the accompanying transmittal letter,
Mercury's counsel reasserted its claim that the bidding diaries contained no material information.  
18.    The ultimate materiality of the diaries, however,  is not dispositive of the issue of Mercury's
responsiveness to the Letter of Inquiry.  As noted above the Letter of Inquiry requested all documents
referring or relating to Mercury's bidding strategy.  These bidding diaries were a contemporaneous record
of Mercury's bidding activity by those persons at Mercury conducting the bidding.  We find it difficult to
imagine a reasonable interpretation of WTB's request that would exclude these diaries.  The officers of
Mercury, not being newcomers to the telecommunications industry, should have known that Mercury was
required to produce these diaries, and if its failure to do so was based on advice of counsel, it was ill-served
by that advice.  However, we have no basis to believe that Mercury's failure to produce the diaries was
the result of a willful intent to conceal information.  Mercury ultimately did produce the diaries when they
were requested specifically, and the information provided only served to confirm what Mercury had already
admitted to regarding its use of trailing numbers.  Because intent to deceive is an essential element of lack
of candor, we are unwilling to find that Mercury lacked candor in its response to Question Five of the
Letter of Inquiry.  
19.    High Plains also claims that Mercury lacked candor in its response to Question Seven of the
Letter of Inquiry, which asked Mercury to identify all markets in which it placed bids using bid signals,
but did not intend to win.  In response, Mercury stated the following:

          None.  In each instance where Mercury placed a bid it structured its bid in such a manner
     that it was prepared to accept and pay for the license if it were the highest bidder at the
     auction's end.  Clearly, Mercury bid on markets that were not included on its list of target
     markets (see Schedule 6).  In many instances, this reflected only an appropriate desire to
     "park pops" and thereby protect eligibility without disclosing overall bidding strategies. 
     See also Mercury's response to Question 4 for a further explanation of such bids and a
     listing of all markets for which Mercury's bids did not end with "000".[]

High Plains argues that Mercury bid in certain markets solely for the purpose of signaling competing
bidders to stop bidding in other markets in which Mercury was truly interested.  However, Mercury did
not withdraw bids in any of the markets where it used bid signals, and High Plains provides no evidence of
Mercury's alleged lack of intent to accept and pay for certain markets.  In the absence of such evidence, we
are unwilling to find that Mercury lacked candor in this response.

20.    High Plains further contends that Mercury responded untruthfully to Question Eight of the
Letter of Inquiry, which asked Mercury to identify each instance where it placed a retaliatory bid and the
result that Mercury was seeking to achieve by placing each such bid.  Mercury responded as follows:
          Mercury did not use pure retaliatory bidding.  Attachment 4 sets forth the complete history
     of Mercury's use of Trailing Numbers.  In some instances identified therein, Mercury
     employed Trailing Numbers in a manner intended to posture, threatened [sic] and compete
     for markets based on bids submitted by others in prior rounds.  In no instance did any such
     bid reflect an agreement or solicitation to do or forebear from doing anything with respect
     to subsequent bidding.  Nor did Mercury intend any such bids to convey any information
     concerning Mercury's bidding strategies.[]

We find Mercury's response to be contradictory.  Mercury denies that it used trailing numbers to convey
information or solicit action from competing bidders,  yet at the same time, Mercury admits that it used
trailing numbers to threaten competing bidders.  Such threats necessarily communicate information and
seek to influence the actions of competing bidders.  However, even if we were to conclude that Mercury's
answer was internally inconsistent, we do not find that it was untruthful.  In its response to the Letter of
Inquiry, Mercury fully disclosed all instances in which it used trailing numbers in bids, and discussed its
reasons for doing so in detail.  We find no evidence that Mercury intended to deceive or mislead the
Commission in its response to this question. 

21.    Finally, High Plains claims that Mercury lacked candor in its response to Question Nine of the
Letter of Inquiry.  Question Nine asked Mercury to "[i]dentify every auction participant or other
individual who you believe ceased bidding in one of Mercury's targeted markets in response to a retaliatory
bid placed by Mercury."  In response, Mercury provided charts showing its relevant bidding history. 
These charts listed Mercury's bids in which the trailing numbers corresponded with the identification
numbers of other markets in which Mercury was bidding.  They also showed the subsequent bids of the
competing bidders in those markets.  However, Mercury qualified its response by stating that it could not
be certain why a particular bidder ceased bidding in a given market because Mercury never had any
communications or agreements with any other bidder on this subject, either verbal or in writing.  We do not
believe this response demonstrates an intent to deceive the Commission.  Mercury candidly disclosed the
bids in which trailing numbers were used and the bids of other bidders in markets corresponding to those
trailing numbers, but declined to speculate why a particular bidder may have ceased bidding in a given
market.  High Plains fails to identify any communications, agreements or other evidence demonstrating that
Mercury had knowledge of why a particular bidder ceased bidding in a given market.  Therefore, we find
no merit in High Plains' claim.
     
          C.  Ex Parte Communications

22.    High Plains also seeks review of rulings by the Bureau and the Office of General Counsel
(OGC) rejecting High Plains' allegations that Mercury violated the Commission's ex parte rules. According
to High Plains, in the weeks leading up to the Bureau's August 21 action conditionally granting 23 of
Mercury's applications, the Commission received at least 27 letters from members of Congress regarding
those pending applications.  In its initial letter ruling and the OGC Letter Decision on Reconsideration,
OGC rejected the allegations that Mercury's solicitation of congressional support involved misconduct or
undermined the integrity of the Commission's processes.    OGC found that the congressional letters and
telephone calls involved no significant violation of the Commission's ex parte rules.  The Bureau similarly
rejected High Plains' allegations that Mercury committed significant violations of the ex parte rules. 
23.    We disagree with High Plains' contentions that the OGC's analysis of the ex parte question was
wrong and that a serious violation of the ex parte rules warranting designation for hearing of Mercury's
licenses had occurred.  High Plains does not dispute that the congressional letters, submitted on Mercury's
behalf, were served on High Plains, and presents no evidence that any delay in service was deliberate or
intended to prejudice High Plains.  Our review of the record indicates that by August 1, 1997,  High Plains
had been served with at least 12 congressional letters, thereby giving High Plains notice of the thrust of the
congressional concerns well before the Bureau issued its initial licensing decision on August 21, 1997.  All
seven congressional letters sent in September-October 1997 were also served on High Plains, and all but
one were served the same day that they were filed.  These facts confirm both that Mercury made a
reasonable effort to achieve service and that High Plains was not prejudiced by any failure by Mercury to
ensure timely service.  Additionally, High Plains presents no evidence to challenge OGC's finding that the
telephone calls were legitimate status inquiries.
24.    In view of the foregoing, the cases cited by High Plains do not support designating for
hearing Mercury's applications or revoking Mercury's licenses for ex parte violations, even though the
number of congressional contacts here was greater.  Unlike all three of these cases, the letters were in fact
served, albeit not always in a timely fashion, and Mercury informed the authors of the letters of the need for
service.  In contrast to Stearns, the only one of these cases in which the violator's application was
dismissed, Mercury had not been expressly warned to avoid repetition of an ex parte violation.
25.    High Plains also disputes OGC's conclusion that there was no improper congressional intrusion
into the Commission's decisional process.  High Plains asserts that the congressional letters improperly
addressed the merits of Mercury's applications and that they "imply" a preference for Mercury.  High
Plains also asserts that the sheer volume of congressional correspondence created undue pressure on the
Commission and that even pressure related to timing is improper. 
26.    We find no basis to overturn OGC's conclusions.  Although the volume of letters filed on
Mercury's behalf was high, they did not improperly intrude into the decisional process.  The substance of
the letters was that action on Mercury's applications not be delayed pending the outcome of the
investigations.   The letters express support for an "unfettered" investigation into the issue of whether
Mercury violated the bid signaling rule.  The letters expressed no opinion as to how the investigations
should be resolved or what sanction (potentially including license revocation), if any, should be imposed. 
Accordingly, we deny High Plains' application for review as to the OGC Letter Decision on
Reconsideration.        
                                     
                        IV.  CONCLUSION
27.    After carefully reviewing High Plains' applications for review of the WTB Order on
Reconsideration and the OGC Letter Decision on Reconsideration, we conclude that High Plains has
failed to present sufficient facts and/or arguments to support its claims that WTB or OGC erred in their
decisions.  Therefore, we deny High Plains' applications for review and affirm the WTB Order on
Reconsideration and the OGC Letter Decision on Reconsideration.  

                      V.  ORDERING CLAUSES
28.    Accordingly, IT IS ORDERED that, pursuant to sections 4(i) and 5(c)(5) of the
Communications Act of 1934, as amended, 47 U.S.C.  154(i) and 155(c)(5), and section 1.115 of the
Commission's rules, 47 C.F.R.  1.115, the Application for Review filed by High Plains Wireless, L.P. on
December 5, 1997, IS DENIED.
29.    IT IS FURTHER ORDERED that, pursuant to sections 4(i) and 5(c)(5) of the
Communications Act of 1934, as amended, 47 U.S.C.  154(i) and 155(c)(5), and section 1.115 of the
Commission's rules, 47 C.F.R.  1.115, the Application for Review filed by High Plains Wireless, L.P. on
May 6, 1998, 1998, IS DENIED.
30.    IT IS FURTHER ORDERED that, pursuant to section 4(i) of the Communications Act of
1934, as amended, 47 U.S.C.  154(i), and section 1.45(c) of the Commission's rules, 47 C.F.R.  1.45(c),
the Reply to Opposition to Application for Review filed by High Plains Wireless, L.P. on January 6, 1998,
IS DISMISSED.
31.    IT IS FURTHER ORDERED that, pursuant to section 4(i) of the Communications Act of
1934, as amended, 47 U.S.C.  154(i), and section 1.45(c) of the Commission's rules, 47 C.F.R.  1.45(c),
the Supplement to Application for Review filed by High Plains Wireless, L.P. on January 13, 1998, IS
DISMISSED.
32.    IT IS FURTHER ORDERED that, pursuant to section 4(i) of the Communications Act of
1934, as amended, 47 U.S.C.  154(i), and section 1.45(c) of the Commission's rules, 47 C.F.R.  1.45(c),
the Supplement to its Opposition to Application for Review filed by Mercury PCS II, LLC on February 20,
1998, IS DISMISSED.
33.    IT IS FURTHER ORDERED that, pursuant to section 4(i) of the Communications Act of
1934, as amended, 47 U.S.C.  154(i), and section 1.45(c) of the Commission's rules, 47 C.F.R.  1.45(c),
the Reply to Mercury's Supplement to Opposition to Application for Review filed by High Plains Wireless,
L.P. on March 5, 1998, IS DISMISSED.


                              FEDERAL COMMUNICATIONS COMMISSION


                              Magalie Roman Salas
                              Secretary
                                APPENDIX A

       Mercury PCS II, LLC Broadband PCS D, E, and F block licenses


Block
Market
Call Sign
File Number
Location


D
B121
KNLG913
01291-CW-L-97
Eagle Pass-Del Rio, TX


E
B191
KNLG919
01297-CW-L-97
Hobbs, NM


E
B246
KNLG922
01300-CW-L-97
Laurel, MS


F
B003
KNLF929
00114-CW-L-97
Abilene, TX


F
B032
KNLG906
01284-CW-L-97
Baton Rouge, LA


F
B040
KNLG907
01285-CW-L-97
Big Spring, TX


F
B042
KNLG908
01286-CW-L-97
Biloxi-Gulfport-Pascagula, MS


F
B052
KNLG909
01287-CW-L-97
Bowling Green-Glasgo, KY


F
B058
KNLG910
01288-CW-L-97
Brunswick, GA


F
B087
KNLG911
01289-CW-L-97
Clovis, NM


F
B115
KNLG912
01290-CW-L-97
Dothan-Enterprise, AL


F
B146
KNLG914
01292-CW-L-97
Florence, AL


F
B154
KNLG915
01293-CW-L-97
Ft. Walton Beach, FL


F
B159
KNLG916
01294-CW-L-97
Gainesville, FL


F
B180
KNLG917
01295-CW-L-97
Hammond, LA


F
B186
KNLG918
01296-CW-L-97
Hattiesburg, MS


F
B195
KNLG920
01298-CW-L-97
Houma-Thibodeaux, LA


F
B236
KNLG921
01299-CW-L-97
Lafayette-New Iberia, LA


F
B263
KNLG923
01301-CW-L-97
Louisville, KY


F
B264
KNLG924
01302-CW-L-97
Lubbock, TX


F
B269
KNLG925
01303-CW-L-97
McComb-Brookhaven, MS


F
B296
KNLG926
01304-CW-L-97
Midland, TX


F
B302
KNLG927
01305-CW-L-97
Mobile, AL


F
B305
KNLG928
01306-CW-L-97
Montgomery, AL


F
B327
KNLG929
01307-CW-L-97
Odessa, TX


F
B340
KNLG930
01308-CW-L-97
Panama City, FL


F
B343
KNLG931
01309-CW-L-97
Pensacola, FL


F
B400
KNLG932
01310-CW-L-97
San Angelo, TX


F
B415
KNLG933
01311-CW-L-97
Selma, AL


F
B439
KNLG934
01312-CW-L-97
Tallahassee, FL


F
B454
KNLG935
01313-CW-L-97
Valdosta, GA


F
B467
KNLG936
01314-CW-L-97
Waycross, GA