Mr. Suri?

Mr.

Chief Justice, and may it please the Court, I think it would be helpful if, before I invite the Court's questions, I explain exactly the sense in which we mean FCC forfeiture orders are not binding.

And I think the best way to do that is to point out three differences between FCC penalties and the SEC penalties that were at issue in Jarcacy.

The first difference is that although the SEC could file a recovery action in order to recover a penalty it had imposed, it didn't have to do that.

It also had its own administrative tools with which to collect the penalties.

For example, it could ask the IRS to deduct the amount of the penalty from your tax refund, or it could try to garnish your wages.

And I want to know how you think we should deal with that and respond to that concern.

Mr. Suri?

Mr.

Chief Justice, and may it please the Court, I think it will be helpful if before I invite the Court's questions, I explain exactly the sense in which we mean FCC forfeiture orders are not binding, and I think the best way to do that is to point out three differences between FCC penalties and the SEC penalties that were is-- at issue in Jarkesy.

The first difference is that although the SEC could file a recovery action in order to recover a penalty it had imposed, it didn't have to do that.

It also had its own administrative tools with which to collect the penalties.

For example, it could ask the IRS to deduct the amount of the penalty from your tax refund, or it could try to garnish your wages, and of course, there's no path to a jury trial if it does that.

For the FCC, however, the only way it can get to the penalties is to file this collection suit where you do get a jury trial.

Yes.