Before the

FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554
In the Matter of

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Application for Consent to Assignment of
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Broadcast Station Construction Permit or License )
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ASSIGNOR: KTVU, LLC, a subsidiary of
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Cox Media Group, LLC, a Delaware company
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ASSIGNEE: Fox Television Stations, Inc.
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a Delaware company
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__________________________________________)

File No. BALCDT-20140701ABV
Facility ID Nos. 35703, 34564, &
34565

PETITION TO DENY
APPLICATION FOR CONSENT TO ASSIGNMENT OF
BROADCAST STATION LICENSE

Dr. Albert Wang, Chair
Joel Wong, President
Asian Pacific Islander American Public Affairs Association (APAPA)
San Francisco Bay Area Region
4000 Truxel Road, Suite 3
Sacramento, CA 95834
Christopher C. Zhang, Esq.
CA Bar #271179
12175 Saratoga-Sunnyvale Rd, Suite C
Saratoga, CA 95070

PETITION TO DENY
APPLICATION FOR CONSENT TO ASSIGNMENT OF BROADCAST STATION
LICENSE
The Asian Pacific Islander American Public Affairs Association (“APAPA” or
“Petitioner”)!respectfully submits this Petition to Deny the Application for Consent to
Assignment of Broadcast Station License, of station licenses KTVU, KICU-TV, K29AB,
Facility ID Numbers 35703, 34564, and 34565, respectively, from Cox Media Group, LLC
(“Cox”), to Fox Television Stations, LLC (“Fox TV”), pursuant to the Communications Act of
1934, as amended, 47 U.S.C. §309(d), and the Federal Communications Commission’s Rules, 47
C.F.R. §1.939.

PETITIONER
Petitioner, APAPA, is a national non-profit, non-partisan, grassroots organization
founded in 2001, with 7 regions and many chapters throughout the U.S. APAPA’s mission is to
promote the advancement of Asian and Pacific Islander (API) Americans through active
participation and leadership in civic and public affairs. Its San Francisco Metropolitan Bay Area
(“Bay Area”) Region has a significant presence in the Asian American community and the
diverse Bay Area.
APAPA has standing as a party of interest, as a responsible representative of the public
audience in the local market. As shown in the attached Declarations1, many of APAPA’s
officers, employees and constituents regularly watch Fox News Channel (“Fox News”), KTVU,
KICU-TV, and/or K29AB, and will be harmed if the assignment is granted.

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1
Exhibit 1

THE STATIONS
The stations in question, KTVU, KICU-TV, and K29AB, are all operated within the Bay
Area. The proposed assignment would transfer all three station licenses from Cox to Fox TV, a
subsidiary of Fox Entertainment.

FACTS
FTS is owned by Fox Entertainment Group, Inc. (“Fox Group”), which also owns and
operates Fox News, a cable and satellite television channel. Fox News’ programming includes a
permanent series, “The Five.” The Five includes five show hosts, including Mr. Robert!Gilliland
Beckel, commonly known as Bob Beckel.
Bob Beckel, as sanctioned by Fox News and Fox Group, has repeatedly used the TV
segment to promote hatred, bigotry, unfounded fear, profanities, obscenities, and intolerance
targeting minority groups.
In August 2012, Beckel referred to Jewish Americans as “a bunch of diamond merchants
we don’t know the names of.” 2
In November 2012, Beckel concluded, that San Francisco nudists were, as children,
“probably gang-banged, I don’t know!” and that “they were probably sexually assaulted, I don’t
know!”3
In February 2013, Beckel stated that that rapes on campus do not really happen and
asserted that victims of date rape aren’t going to “take a gun out and shoot [their] date.”4
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2
See http://www.algemeiner.com/2012/08/08/fox-news-host-romneys-israel-fundraiser-heldwith-bunch-of-diamond-merchants/
3
See http://www.huffingtonpost.com/2012/11/21/fox-nudists-gang-banged_n_2171054.html
4
See http://www.huffingtonpost.com/2013/02/20/bob-beckel-college-rapeguns_n_2726173.html

In September 2013, Beckel proposed “no Muslim students coming here with visas. No
more mosques being built here until you stand up and denounce what's happened in the name of
your prophet.”5
In July 2014, Beckel stated, “the Chinese are the single biggest threat to the national
security of the U.S. They have been, they will be and they can wait, they're very patient. Do you
know what we just did? As usual, we bring them over here and we teach a bunch of Chinamen -err, Chinese people -- how to do computers and then they go back to China and hack into us.” At
the same time of the commentary, Beckel made an obscene gesture to the TV camera.6
In additional to the offenses above, Beckel has repeatedly used obscenities and
profanities on live television.7 For example, in April 2012, Beckel appeared on Hannity on Fox
News and said “You don’t know what the f--- you're talking about!”8 In August, 2012, Beckel
said “"I wont diminish myself to where Republicans or free pussy…”9 Later in the same month,
Beckel said “You know, you do that one more time, you're f---ing—”10 At one point, Beckel
admitted, in reference to a profane remark he just make, “I’m going to be fired.”11 However,
Fox TV did nothing to discipline Beckel, and instead allows these hate speeches and profanities
to continue.
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5
See http://www.huffingtonpost.com/2013/07/11/bob-beckel-anti-muslimcomments_n_3581419.html
6
See http:// ww.huffingtonpost.com/2014/07/10/bob-beckel-chinamen-thefive_n_5575873.html
7
See generally http://www.huffingtonpost.com/news/bob-beckel-fox-news/
8
See http://www.huffingtonpost.com/2012/04/17/fox-news-bob-beckel-fbomb_n_1430863.html
9
See http://www.huffingtonpost.com/2012/08/07/bob-beckel-reince-preibusname_n_1752005.html
10
See http://www.huffingtonpost.com/2012/08/15/bob-beckel-f-bomb-foxnews_n_1778200.html
11
See http://www.theblaze.com/stories/2012/04/16/im-going-to-be-fired-bob-beckel-detonatesa-high-volume-what-the-f-live-on-hannity/

The Bay Area is a diverse region with many minorities contributing to its culture and
success. At the 2010 census, minorities in the Bay Area made up 47.5% of the local population,
wherein 23.3 of the population are Asian Americans.12 Asian Americans, Latinos, Muslim
Americans, and LGBT have long been living together in an environment that values tolerance
and respect. This is the same environment in which the three stations in question broadcast.
One of the three stations, KTVU, has a history of making racist comments. Following
the Asiana crash at San Francisco airport in 2013, KTVU named the four pilots onboard the
flight, as “Sum Ting Wong, Wi Tu Lo, Ho Lee Fuk and Bang Ding Ow.” Three producers were
fired from the station in the aftermath.13

ARGUMENT
Petitioner hereby submits that it has made specific allegations of fact sufficient to make a
prima facie showing that the petitioner is a party in interest and that a grant of the application
would be inconsistent with the public interest, convenience and necessity, pursuant to the
Commission’s Rules, 47 C.F.R. 1.939(d).
As stated above, Bob Beckel has engaged in a consistent pattern of racist, misogynistic,
sexist, and anti-minority hate speech. Using racial slurs, derogatory terms, profanities, obscene
gestures, and unsubstantiated claims, Bob Beckel incites xenophobia, intimidates minorities,
encourages hatred, and divides our country and community. Repeated targeting of minorities
harms public safety and social welfare.
Fox News has condoned Beckel’s repeated behavior of targeting minorities by keeping
him on The Five, and making The Five a permanent series. Fox News has ignored repeated
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12
http://www.bayareacensus.ca.gov/bayarea.htm
13
See http://mashable.com/2013/07/25/ktvu-producers-fired/

requests to stop Beckel’s hate speech, and install internal protocols to prevent future incidents.
In addition, Fox News has a clear track record of distorting and misrepresenting information
aimed at misleading the viewing public.14
The San Francisco Bay Area is a particularly diverse community and vulnerable to
languages that pit different groups against one another. The Silicon Valley, in the southern part
of the Bay Area, owes much of its success to immigrant engineers who are law-abiding
citizens.15 Instilling fear in the hearts of these contributing members of society, many of whom
are people of color, not only threatens the local economy, but also causes American citizens to be
unnecessarily questioned for their loyalty.
If assigned to Fox TV and Fox Group, the three stations in question would be subject to
the same lax protocols and sanction of hatred as demonstrated by Fox News. The unscrupulous
greed for higher rating would drive the three stations to adopt extreme and outrageous TV
personalities and languages. As Fox News has been oblivious to the public outcry, so will the
three stations be indifferent to the Bay Area’s unique diverse culture. More hate pundits like
Bob Beckel would find tenures at Fox News and these local stations. The only remedy is for the
Commission to intervene and stop these offenses from propagating throughout parts of the
country.

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14
See “The Ten Most Egregious Fox News Distortions,” available at
http://www.huffingtonpost.com/2009/10/20/the-ten-most-egregious-fo_n_327140.html
15
See Monthly Labor Review, “Asians in the U.S. labor force: profile of a diverse population,”
Bureau of labor statistics, Mary!D.!Allard,!Nov.!2011,!pp. 12-14, available at
http://www.bls.gov/opub/mlr/2011/11/art1full.pdf

CONCLUSION
WHEREFORE, in view of the above, Petitioner respectfully requests that the
Commissioners deny the Application, or alternatively, grant a hearing on the Application,
pursuant to 47 U.S.C. §309(e).

Respectfully submitted,
_____/s/________________________
Dr. Albert Wang, Chair
Joel Wong, President
Asian Pacific Islander American Public Affairs Association (APAPA)
Bay Area Region
4000 Truxel Road, Suite 3
Sacramento, CA 95834
Christopher C. Zhang, Esq.
CA Bar #271179
12175 Saratoga-Sunnyvale Rd, Suite C
Saratoga, CA 95070
Dated: August 6, 2014

Exhibit 1

Declarations

DECLARATION OF JOEL WONG
1. I, Joel Wong, President of Bay Area Region of Asian Pacific Islander American Public
Affairs Association (APAPA), do freely give this declaration. APAPA is headquartered at
4000 Truxel Road, Suite 3, Sacramento, CA 95834 and has regions, chapters, and
constituents across the nation.
2. APAPA is a 13-year-old non-profit, non-partisan organization dedicated to promoting the
advancement of Asian and Pacific Islander (API) Americans through active participation and
leadership in civic and public affairs, educating the public about public policy, and providing
opportunities for our youth to gain firsthand knowledge and experience in governmental and
public affairs.
3. Within APAPA constituency are many viewers of Fox News, KTVU, KICU-TV, or K29AB,
who reside in the San Francisco Bay Area. APAPA’s constituents will be harmed, especially
Chinese Americans, if KFI’s license is renewed.
4. Approving the assignment of station licenses would harm APAPA’s constituents and
community because it would allow KTVU, KICU-TV, K29AB, Fox News, and the
employees of these stations to use derogatory language and hate speech over commercial
radio broadcasts. Fox News has a track record of harassing, insulting, and defaming people
who share same or similar characteristics as APAPA’s constituents
5. I will personally be harmed by KFI’s proposed license renewal. As a viewer of Fox News
and KTVU, a Chinese American, and a senior engineer, Division Leader, and Assistant
Department Head of Lawrence Livermore National Laboratory, where I was then the highest
ranking Asian American employee, I have been tremendously offended by the racial slurs
and derogatory language used by Fox News and its employees. As a result, my prior work

has be tainted. My loyalty to this country is cast into doubt. My feelings are not unique.
Derogatory language and speech may have a profound effect on members of marginalized
groups, particularly children and teenagers. The offensive language by Fox News and its
employees will impact the immigrant and other minority communities in the future, as it has
in the past. The consent to assignment of KTVU, KICU-TV, and K29AB’s licenses would
severely impair vulnerable communities from escaping stereotypes, and would have an
equally destructive impact in protecting these communities from potential persecution and
violence.
6. This affidavit has been prepared in support of the foregoing Petition to Deny the Application
for Consent to Assignment of Broadcast Station License.
7. This statement is true to my personal knowledge, and is made under penalty of perjury of the
laws of the United States of America.

Date Executed: August 6, 2014

____/s/________________________________
Joel Wong, President
Bay Area Region
APAPA

CERTIFICATE OF SERVICE
I, Christopher Zhang, hereby certify that the foregoing Petition to Deny the Application for
Consent to Assignment of Broadcast Station License was served upon the following parties via
email and USPS Certified Mail on this 6th day of August, 2104:
KTVU, LLC
Michael D. Basile, ESQ.
Cooley LLP
1299 Pennsylvania NW
Suite 700
Washington, DC 20004
MDBASILE@COOLEY.COM
Fox Television Stations, Inc.
Mace J. Rosenstein, Esq.
Covington & Burling
1201 Pennsylvania Ave NW
Suite 890
Washington, DC 20004
MROSENSTEIN@COV.COM

!

______/s/_________________________________
Christopher Zhang, Esq.
12175 Saratoga-Sunnyvale Rd, Suite C
Saratoga, CA 95070