cal inaccuracies and offensive statements or characterizations
   in the show.
   Notwithstanding the requirement in 47 C.F.R. s 73.1202
   that a licensee keep and make available all letters received
   from viewers, WUSA-TV in Washington, D.C., forwarded the
   letters it received to CBS's main office in New York. When a
   representative of the Ukrainian-American Community Net
   work asked to see the letters, WUSA contacted CBS in New
   York and was told by Raymond Faiola that the letters were
   in storage and that a response had been sent to each viewer
   who wrote in; Faiola attached what he said was a copy of that
   response. After failing to locate any viewer who had received
   such a reply, the UACN representative questioned this story.
   A CBS attorney in turn questioned Faiola, who then ex
   plained that the response letter had been sent to only about a
   quarter of the viewers who had written in about the program.
   When an intensive advertising campaign, however, failed to
   turn up even one person in the Ukrainian-American commu
   nity who had received a response, the UACN representative
   complained to the Commission and sent a copy of the com
   plaint to counsel for CBS. When CBS's counsel asked Faiola
   for an affidavit confirming his story, Faiola admitted that the
   letter he had sent WUSA had been merely a draft and that he
   had forgotten to have any actual response letters sent out.
   Nos. 95-1385, 1440. Alexander Serafyn, an American of
   Ukrainian ancestry, petitioned the Commission to deny or to
   set for hearing the application of CBS to be assigned the
   licenses of two stations, arguing that the "60 Minutes" broad
   cast showed that CBS had distorted the news and therefore
   failed to serve the public interest. In support of his petition,
   Serafyn submitted the broadcast itself, outtakes of interviews
   with Rabbi Bleich, viewer letters, a dictionary supporting his
   claim about the mistranslation of "zhyd," historical informa
   tion about the Galicia Division, information showing that CBS
   had rebuffed the offer of a professor of Ukrainian history to
   help CBS understand the subject, and seven other items of
   evidence.
   Serafyn also submitted evidence that "60 Minutes" had no
   policy against news distortion and indeed that management
   considered some distortion acceptable. For example, accord
   ing to the Washington Post, Mike Wallace, a longtime report
   er for "60 Minutes," told an interviewer: "You don't like to
   baldly lie, but I have." Colman McCarthy, The TV Whisper,
   Wash. Post, Jan. 7, 1995, at A21. Don Hewitt, the executive
   producer of "60 Minutes," is quoted in the same article as
   saying that some deception is permissible because "[i]t's the
   small crime vs. the greater good," and elsewhere as saying
   that "I wouldn't make Hitler look bad on the air if I could get
   a good story." Richard Jerome, Don Hewitt, People, Apr. 24,
   1995, at 85, 90.
   CBS, taking the position that any official investigation into
   its news broadcasting "offends the protections of a free
   press," did not submit any evidence. Nonetheless, the Com
   mission denied the petition without a hearing. See WGPR,
   Inc., 10 FCC Rcd 8140, 8146-48 (1995). Explaining that it
   would not investigate an allegation of news distortion without
   "substantial extrinsic evidence" thereof, the Commission de
   termined that only three of Serafyn's items of evidence were
   extrinsic to the broadcast itself: the viewer letters, the
   outtakes of interviews with Rabbi Bleich, and CBS's refusal
   to use the services of the history professor. All the other
   evidence, according to the Commission, either concerned "dis
   putes as to the truth of the event ... or embellishments
   concerning peripheral aspects of news reports or attempts at
   window dressing which concerned the manner of presenting
   the news." Id. at 8147 (emphasis in original, citations omit
   ted). The Commission then held that the three items it
   regarded as extrinsic evidence "in total ... do[ ] not satisfy
   the standard for demonstrating intent to distort." Id. at
   8148. Serafyn had therefore failed to show that CBS had not
   met its public interest obligations and had "failed to present a
   substantial and material issue of fact that the grant of the
   application ... would be inconsistent with the public inter
   est." Id. at 8149.
   Serafyn and Oleg Nikolyszyn, another viewer who com
   plained to the Commission and whose appeal we consolidated
   with Serafyn's, argue that the Commission violated its own
   standard in concluding that no hearing was necessary.
   Serafyn implicitly objects also to the standard itself insofar as
   he argues that it "imposed an impossible burden" upon him
   by requiring that he present extrinsic evidence sufficient to
   prove his claim without the benefit of discovery, and that the
   "objective" evidence he offered should be deemed adequate to
   warrant a hearing upon the public interest question.
   No. 95-1608. Serafyn and the Ukrainian Congress Com
   mittee of America also petitioned the Commission to revoke
   or set for a revocation hearing all of the broadcast licenses
   owned by CBS, arguing that CBS had made misrepresenta
   tions to the Commission regarding its treatment of the viewer
   letters. The Commission denied the petition on the grounds
   that Serafyn had neither alleged that CBS made a false
   statement to the Commission (as opposed to WUSA) nor
   proved that CBS intended to make a false statement. With
   respect to the latter point the Commission relied solely upon
   Fiola's affidavit; it did not consider Serafyn's allegations
   that CBS intentionally misrepresented the facts because they
   were "not supported by an affidavit from a person with
   personal knowledge thereof" and therefore did not meet the
   threshold requirement of s 309(d). See Stockholders of CBS
   Inc., 11 FCC Rcd 3733 (1995).
   CONTENTS:
   Title Page
   I. Background
   II. News Distortion
   A. Evidentiary standard
   B. Licensee's policy on distortion
   C. Nature of particular evidence
   1. Extrinsic evidence
   (a) Outtakes of the interview with Rabbi Bleich
   (b) The viewer letters
   (c) The refusal to consult Professor Luciuk
   2. Evidence of factual inaccuracies
   D. Misrepresentation
   III. Conclusion
   II. News Distortion
   With regard to the Commission's requirement that he
   prove by extrinsic evidence that CBS intended to distort the
   news, Serafyn argues that the Commission "has never articu
   lated a precise definition of 'extrinsic evidence' " and that its
   prior decisions suggest it is merely seeking "objective evi
   dence from outside the broadcast which demonstrates, with
   out any need for the Commission to second-guess a licensee's
   journalistic judgment or for the Commission to make credibil
   ity findings, that the licensee has distorted a news program."
   He then argues that the Commission misapplied the extrinsic
   evidence standard by mischaracterizing some evidence as
   non-extrinsic, failing to discuss other evidence he presented,
   analyzing each piece of extrinsic evidence separately rather
   than cumulatively, and requiring him to prove his case rather
   than simply to raise a material question.
   The Commission stands by its characterization of the evi
   dence based upon its definition of extrinsic evidence, which it
   says " 'is evidence outside the broadcast itself,' such as evi
   dence of written or oral instructions from station manage
   ment, outtakes, or evidence of bribery." Further, the Com
   mission explains that its investigation properly "focuse[d] on
   evidence of intent of the licensee to distort [deliberately], not
   on the petitioner's claim that the true facts of the incident are
   different from those presented," because "[e]xtrinsic evidence
   [must] demonstrate[ ] that a broadcaster knew elements of a
   news story were false or distorted, but nevertheless, proceed
   ed to air such programming."
   We review the Commission's decision under the arbitrary
   and capricious standard. See Astroline, 857 F.2d at 1562.
   We will uphold the decision if it is "reasonable and supported
   by the evidence before it," but "will not 'hesitate to intervene
   where the agency decision appears unreasonable or bears
   inadequate relation to the facts on which it is purportedly
   based.' " Beaumont Branch of the NAACP v. FCC, 854 F.2d
   501, 507 (D.C. Cir. 1988) (quoting California Public Broad
   casting Forum v. FCC, 752 F.2d 670, 675 (D.C. Cir. 1985)).
   Analyzing the Commission's decision under this standard, we
   conclude that the agency has failed adequately to explain its
   decision not to set the application of CBS for a hearing. We
   therefore vacate the decision of the Commission and remand
   the matter for further administrative proceedings.
   CONTENTS:
   Title Page
   I. Background
   II. News Distortion
   A. Evidentiary standard
   B. Licensee's policy on distortion
   C. Nature of particular evidence
   1. Extrinsic evidence
   (a) Outtakes of the interview with Rabbi Bleich
   (b) The viewer letters
   (c) The refusal to consult Professor Luciuk
   2. Evidence of factual inaccuracies
   D. Misrepresentation
   III. Conclusion
   A. Evidentiary standard
   At the outset, we note that the Commission never explained
   under which step of the inquiry it resolved this case. It
   began by stating that Serafyn "must satisfy the threshold
   extrinsic evidence standard in order to elevate [his] allega
   tions to the level of 'substantial and material' "; but then said
   that Serafyn had not "demonstrate[d]" that CBS intended to
   distort the news; and finally concluded that because his
   allegations concerned only one show "such an isolated in
   stance ... cannot[ ] rise to the level of a 'pattern of preju
   dice,' the burden required of a petitioner who seeks to make a
   prima facie case." WGPR, 10 FCC Rcd at 8148. The
   Commission's muddled discussion suggests that it not only
   conflated the first and second steps but also applied the
   wrong standard in judging the sufficiency of the evidence.
   As we have explained, the appropriate questions for the
   Commission to ask at the threshold stage are first, whether
   the petitioner's allegations make out a prima facie case, and
   second, whether they raise a substantial and material ques
   tion of fact regarding the licensee's ability to serve the public
   interest. Instead, the Commission apparently asked whether
   Serafyn's evidence proved CBS's intent to distort the news,
   for it concluded by saying:
   [W]e find, in sum, that the outtakes of the rabbi's inter
   view fail to demonstrate CBS's intent to distort....
   The two remaining pieces of evidence ... fall[ ] far
   short of demonstrating intent to distort.... Serafyn's
   extrinsic evidence in total, therefore, does not satisfy the
   standard for demonstrating intent to distort.
   Id. at 8147, 8148. In requiring Serafyn to "demonstrate" that
   CBS intended to distort the news rather than merely to
   "raise a substantial and material question of fact" about the
   licensee's intent, the Commission has misapplied its standard
   in a way reminiscent of the problem in Citizens for Jazz:
   "The statute in effect says that the Commission must look
   into the possible existence of a fire only when it is shown a
   good deal of smoke; the Commission has said that it will look
   into the possible existence of a fire only when it is shown the
   existence of a fire." 775 F.2d at 397. For this reason alone
   we must remand the case to the agency. Although we do not
   propose to determine just how much evidence the Commis
   sion may require or whether Serafyn has produced it, which
   are matters for the Commission itself to determine in the first
   instance, we can safely say that the quantum of evidence
   needed to raise a substantial question is less than that
   required to prove a case. See id. (" '[P]rima facie sufficiency'
   means the degree of evidence necessary to make, not a fully
   persuasive case, but rather what a reasonable factfinder
   might view as a persuasive case--the quantum, in other
   words, that would induce a trial judge to let a case go to the
   jury even though he himself would (if nothing more were
   known) find against the plaintiff").
   We are also concerned about the Commission's method of
   analyzing the various pieces of evidence that Serafyn present
   ed. In making its decision the Commission must consider
   together all the evidence it has. See Gencom, 832 F.2d at
   181; Citizens for Jazz, 775 F.2d at 395. The decision under
   review, however, suggests (though not conclusively) that the
   Commission analyzed each piece of evidence in isolation only
   to determine, not surprisingly, that no item by itself crossed
   the threshold. See WGPR, 10 FCC Rcd at 8147-48. Be
   cause we must remand this matter in any case, we need not
   determine whether the Commission in fact erred in this
   regard. We simply note that upon remand the Commission
   must consider all the evidence together before deciding
   whether it is sufficient to make a prima facie case or to raise
   a substantial and material question of fact.
   CONTENTS:
   Title Page
   I. Background
   II. News Distortion
   A. Evidentiary standard
   B. Licensee's policy on distortion
   C. Nature of particular evidence
   1. Extrinsic evidence
   (a) Outtakes of the interview with Rabbi Bleich
   (b) The viewer letters
   (c) The refusal to consult Professor Luciuk
   2. Evidence of factual inaccuracies
   D. Misrepresentation
   III. Conclusion
   B. Licensee's policy on distortion
   In addition to holding that Serafyn presented insufficient
   evidence to "demonstrate" that CBS had intentionally distort
   ed the "60 Minutes" episode about Ukraine, the Commission's
   denial of Serafyn's petition also rested upon the alternative
   ground that he had not alleged a general pattern of distortion
   extending beyond that one episode. Upon appeal Serafyn
   argues--and the Commission does not dispute--that he did
   present evidence regarding CBS's general policy about distor
   tion, namely the comments of Wallace and Hewitt quoted
   above, and that the Commission failed to discuss or even to
   mention this evidence. Both Wallace's comment ("you don't
   like to baldly lie, but I have") and Hewitt's ("it's the small
   crime vs. the greater good") are, to say the least, suggestive.
   Furthermore, both Wallace (as the most senior reporter and
   commentator for "60 Minutes") and Hewitt (as the producer
   of the series) are likely members of the "news management"
   whose decisions can fairly be attributed to the licensee.
   Hunger in America, 20 FCC 2d at 150. The Commission's
   failure to discuss Serafyn's allegation relating to CBS's policy
   on veracity is therefore troubling. Indeed, because of the
   importance the Commission placed upon the supposed lack of
   such evidence, its presence in the record casts the Commis
   simon alternative ground into doubt. The Commission must
   consider these allegations upon remand.
   CONTENTS:
   Title Page
   I. Background
   II. News Distortion
   A. Evidentiary standard
   B. Licensee's policy on distortion
   C. Nature of particular evidence
   1. Extrinsic evidence
   (a) Outtakes of the interview with Rabbi Bleich
   (b) The viewer letters
   (c) The refusal to consult Professor Luciuk
   2. Evidence of factual inaccuracies
   D. Misrepresentation
   III. Conclusion
   C. Nature of particular evidence
   The Commission gave illogical or incomplete reasons for
   finding non-probative two of the three pieces of evidence it
   determined were "extrinsic." It also failed to discuss individ
   ually certain alleged factual inaccuracies that Serafyn brought
   to its attention. Before discussing the Commission's opinion
   in detail, however, we set out a brief excerpt from the
   transcript of the broadcast.
   MORLEY SAFER, co-host: ... [T]he west [of Ukraine],
   where we go tonight, is on a binge of ethnic national
   ism. "Ukraine for the Ukrainians" can have a fright
   ening ring to those not ethnically correct, especially in
   a nation that barely acknowledges its part in Hitler's
   final solution.
   ... [J]ust about every day of the week, the sounds of
   freedom can be heard, men and women giving voice to
   their particular view of how the new independent
   Ukraine should be governed. They disagree about
   plenty, but do have two things in common: their old
   enemy, Russian communism, and their old, old enemy,
   the Jews.
   Unidentified Man # 1: (Through Translator) We Ukrain
   ians not have to rely on American [sic] and kikes.
   SAFER: Yacoov [sic] Bleich left the United States five
   years ago to take over as the chief rabbi for the
   Ukraine.
   Rabbi YACOOV [sic] BLEICH: There is, obviously, a lot
   of hatred in these people that are--that are expound
   ing these things and saying, you know--obviously if
   someone, you know, screams, "Let's drown the Rus
   sians in Jewish blood," there isn't much love lost there.
   ...
   SAFER: ... In western Ukraine at least, Hitler's dream
   had been realized. It was juden-frei, free of Jews. In
   the 50 years since, Jews have drifted in from other
   parts of the old Soviet Union, about 7,000 now in
   [Lviv]. For some Ukrainians, that's 7,000 too many.
   Rabbi BLEICH: Yeah. Well, that's not a secret.
   They're saying that they want the Jews out.
   ...
   SAFER: The western Ukraine is fertile ground for
   hatred. Independence only underlined its backward
   ness: uneducated peasants, deeply superstitious, in
   possession of this bizarre anomaly: nuclear weap
   ons.... Western Ukraine also has a long, dark history
   of blaming its poverty, its troubles, on others.
   [Unidentified] Man # 2: (Through Translator) Kikes
   have better chances here than even the original popu
   lation.
   SAFER: Than the Ukrainians.
   Man # 2: (Through Translator) Yes.
   ...
   SAFER: The church and government of Ukraine have
   tried to ease people's fears, suggesting that things are
   not as serious as they might appear; that Ukrainians,
   despite the allegations, are not genetically anti-Semitic.
   But to a Jew living here ... such statements are little
   comfort....
   Transcript, Joint Appendix at 92-96.
   CONTENTS:
   Title Page
   I. Background
   II. News Distortion
   A. Evidentiary standard
   B. Licensee's policy on distortion
   C. Nature of particular evidence
   1. Extrinsic evidence
   (a) Outtakes of the interview with Rabbi Bleich
   (b) The viewer letters
   (c) The refusal to consult Professor Luciuk
   2. Evidence of factual inaccuracies
   D. Misrepresentation
   III. Conclusion
   1. Extrinsic evidence
   We discuss first the Commission's analysis of the three
   pieces of evidence it found were "extrinsic." The Commission
   has the responsibility to determine the weight of such evi
   dence. The reasons it gives for doing so, however, must be
   reasonable and not unfounded.
   CONTENTS:
   Title Page
   I. Background
   II. News Distortion
   A. Evidentiary standard
   B. Licensee's policy on distortion
   C. Nature of particular evidence
   1. Extrinsic evidence
   (a) Outtakes of the interview with Rabbi Bleich
   (b) The viewer letters
   (c) The refusal to consult Professor Luciuk
   2. Evidence of factual inaccuracies
   D. Misrepresentation
   III. Conclusion
   (a) Outtakes of the interview with Rabbi Bleich
   The outtakes show that all of Rabbi Bleich's quoted com
   ments were made in response to questions about radical
   nationalists. Serafyn argued to the Commission that CBS
   had misrepresented Bleich's views when it broadcast his
   statements without making clear the context in which they
   were spoken and without including the qualifications and
   positive statements that accompanied them. The Commission
   found that the outtakes could indeed "properly serve as
   circumstantial evidence of intent," but went on to find that
   they did not demonstrate an intent to distort the news
   because:
   Rabbi Bleich's latter, allegedly misleading comments im
   mediately followed ... Safer's statement ... that only
   "some Ukrainians" are anti-Semitic.... Indeed, that
   the focus of the "60 Minutes" program was upon only a
   certain sector of the Ukrainian population is evident from
   at least three other express references by Safer to
   "Ukrainian ultranationalist parties," "the Social National
   ists," and other apparently isolated groups of Ukrainians.
   Thus, rather than constitute a distortion, Rabbi Bleich's
   negative comments about Ukrainians as utilized can
   rightly be viewed as limited to only a segment of the
   Ukrainian population.... Nor do we find intent to
   distort because CBS did not include in its episode posi
   tive statements about Ukraine made by Rabbi Bleich....
   [T]he determination of what to include and exclude from
   a given interview constitutes the legitimate "journalistic
   judgment" of a broadcaster, a matter beyond the Com
   mission's "proper area of concern."
   WGPR, 10 FCC Rcd at 8147.
   Serafyn argues upon appeal that the Commission erred in
   failing to find the outtakes persuasive evidence of CBS's
   intent to distort. The Commission was not unreasonable,
   however, in finding that Safer's phrase "some Ukrainians"
   and his other references to extremist groups effectively limit
   ed the scope of Bleich's comments to "a segment of the
   Ukrainian population." Id.
   CONTENTS:
   Title Page
   I. Background
   II. News Distortion
   A. Evidentiary standard
   B. Licensee's policy on distortion
   C. Nature of particular evidence
   1. Extrinsic evidence
   (a) Outtakes of the interview with Rabbi Bleich
   (b) The viewer letters
   (c) The refusal to consult Professor Luciuk
   2. Evidence of factual inaccuracies
   D. Misrepresentation
   III. Conclusion
   (b) The viewer letters
   The Commission held that the letters CBS received from
   viewers were extrinsic evidence because they were "external
   to the program." Id. at 8148. In the Commission's view,
   however, the letters were not probative because the letter
   writers were not
   "insiders," that is, employees or members of manage
   ment of CBS. Nor are they persons with direct personal
   knowledge of intent to falsify.... And letters sent by
   viewers subsequent to the broadcast [are] evidence clear
   ly incapable of going to intent, because intent is a state of
   mind accompanying an act, not following it.
   Id.
   The Commission's reasoning here is flawed in two respects.
   First, a person need not have "direct" personal knowledge of
   intent in order to have relevant information that constitutes
   circumstantial evidence about such intent. See Crawford-El
   v. Britton, 93 F.3d 813, 818 (1996) ("[T]he distinction between
   direct and circumstantial evidence has no direct correlation
   with the strength of the plaintiff's case"); CPBF v. FCC, 752
   F.2d at 679 ("Intent [may] be inferred from the subsidiary
   fact of [a broadcaster's] statements to third parties"). Sec
   ond, evidence that sheds light upon one's intent is relevant
   whether it was prepared before or after the incident under
   investigation; consider, for example, a letter written after but
   recounting words or actions before an event.
   Upon remand, therefore, the Commission may wish to
   consider separately two types of letters. First, there may be
   letters that convey direct information about the producers'
   state of mind while the show was in production. For exam
   ple, Cardinal Lubachivsky charged that the producers misled
   him as to the nature of the show. Second, there are letters
   that point out factual inaccuracies in the show. For example,
   Rabbi Lincoln, a viewer, wrote in about the mistranslation of
   "zhyd." Although letters of this type may not have indepen
   dent significance, they may yet be probative in determining
   whether an error was obvious or egregious, and if so whether
   it bespeaks an intent to distort the facts. See Part II.C.2
   below.
   CONTENTS:
   Title Page
   I. Background
   II. News Distortion
   A. Evidentiary standard
   B. Licensee's policy on distortion
   C. Nature of particular evidence
   1. Extrinsic evidence
   (a) Outtakes of the interview with Rabbi Bleich
   (b) The viewer letters
   (c) The refusal to consult Professor Luciuk
   2. Evidence of factual inaccuracies
   D. Misrepresentation
   III. Conclusion
   (c) The refusal to consult Professor Luciuk
   Serafyn asserted that CBS's refusal to consult Professor
   Luciuk demonstrated its intent to distort the news because
   only someone with no intention to broadcast the truth would
   refuse to use the services of an expert. The Commission
   found that evidence of the broadcaster's decision was extrin
   sic to the program but that it "falls far short of demonstrating
   intent to distort the ... program" because the "[d]etermina
   tion[ ] as to which experts to utilize is a decision solely within
   the province of the broadcaster." WGPR, 10 FCC Rcd at
   8148. Once again, the agency's reasoning is too loose.
   Serafyn raises no question about the broadcaster's discretion
   to decide whom, if anyone, to employ; it is only because the
   broadcaster has such discretion that its ultimate decision may
   be probative on the issue of intent. Before the Commission
   may reject this evidence, therefore, it must explain why
   CBS's decision to employ one expert over another--or not to
   employ one at all--is not probative on the issue of its intent
   to distort.
   CONTENTS:
   Title Page
   I. Background
   II. News Distortion
   A. Evidentiary standard
   B. Licensee's policy on distortion
   C. Nature of particular evidence
   1. Extrinsic evidence
   (a) Outtakes of the interview with Rabbi Bleich
   (b) The viewer letters
   (c) The refusal to consult Professor Luciuk
   2. Evidence of factual inaccuracies
   D. Misrepresentation
   III. Conclusion
   2. Evidence of factual inaccuracies
   In describing what evidence it would accept to substantiate
   Serafyn's claim of news distortion, the Commission stated
   that it has "long ruled that it will not attempt to judge the
   accuracy of broadcast news reports or to determine whether a
   reporter should have included additional facts." WGPR, 10
   FCC Rcd at 8147. In "balancing First Amendment and
   public interest concerns," it explained, the Commission
   will not attempt to draw inferences of distortion from the
   content of a broadcast, but it will investigate where
   allegations of news distortion are supported by "substan
   tial extrinsic evidence" that the licensee has deliberately
   distorted its news report. Mrs. J.R. Paul, 26 FCC 2d at
   592. "Extrinsic evidence," that is, evidence outside the
   broadcast itself, includes written or oral instructions
   from station management, outtakes, or evidence of brib
   ery. Hunger in America, 20 FCC 2d at 151. Our
   assessment of allegations of news distortion, in sum,
   focuses on evidence of intent of the licensee to distort,
   not on the petitioner's clam that the true facts of the
   incident are different from those presented.
   WGPR, 10 FCC Rcd at 8147.
   Serafyn argues that the definition quoted above does not
   purport to be all-inclusive, and that the Commission acted
   unreasonably in holding that the evidence he submitted is not
   also extrinsic. In his view the agency should inquire "wheth
   er the licensee has distorted a news program" and the
   Commission can make this inquiry--without becoming a na
   tional arbiter of truth--by relying upon "objective" evidence
   to disprove assertions made in a news show. Intervenor CBS
   argues that the "objective" nature of evidence has never been
   considered in determining whether it is extrinsic. The Com
   mission responds that however one defines "extrinsic evi
   dence," it does not include that which goes only to the truth
   of a matter stated in the broadcast.
   The Commission has not so much defined extrinsic evidence
   as provided examples of the genre and what lies outside it.
   While the Commission certainly may focus upon evidence
   relevant to intent and exclude all else, the problem is--as the
   Commission's past decisions show--that the inaccuracy of a
   broadcast can sometimes be indicative of the broadcaster's
   intent. See Application of WMJX, 85 FCC 2d 251 (1981)
   (station denied intent to mislead public but admitted it knew
   news broadcast was false; Commission implicitly concluded
   from broadcaster's knowledge of falsity that it had intended
   to mislead public); see also Hunger in America, 20 FCC 2d
   at 147 (Commission may intervene "in the unusual case where
   the [truth of the] matter can be readily and definitely re
   solved").
   Here, Serafyn argues that CBS got its facts so wrong that
   its decision to broadcast them gives rise to the inference that
   CBS intentionally distorted the news. Without deciding
   whether Serafyn's arguments about individual facts are cor
   rect, or even specifying what standard the Commission should
   use when analyzing claims of factual inaccuracy, we must
   point out that an egregious or obvious error may indeed
   suggest that the station intended to mislead. This is not to
   say that the Commission must investigate every allegation of
   factual inaccuracy; if the broadcaster had to do historical
   research or to weigh the credibility of interviewees, for
   example, then any alleged inaccuracy is almost certainly
   neither egregious nor obvious. Our point is only that as an
   analytical matter a factual inaccuracy can, in some circum
   stances, raise an inference of such intent. The Commission
   therefore erred insofar as it categorically eliminated factual
   inaccuracies from consideration as part of its determination of
   intent.*
   The chief example we have in mind is the apparent mis
   translation of "zhyd" as "kike." Such a highly-charged word
   is surely not used lightly. Of course, translation is a tricky
   business, and it is axiomatic that one can never translate
   perfectly. Nonetheless, a mistranslation that "affect[s] the
   basic accuracy" of the speaker is problematic under the
   Commission's standard. Galloway, 778 F.2d at 20.
   Translating can be compared to editing a long interview
   down to a few questions and answers. In The Selling of the
   Pentagon, the Commission addressed an interviewee's allega
   tion that CBS's "60 Minutes" had "so edited and rearranged
   [his answers to questions posed] as to misrepresent their
   content." 30 FCC 2d 150, 150 (1971). Although it decided in
   that case that the interviewee had not been so badly misrep
   resented as to require action by the Commission, the agency
   allowed that it "can conceive of situations where the documen
   tary evidence of deliberate distortion would be sufficiently
   strong to require an inquiry--e.g., where a 'yes' answer to
   one question was used to replace a 'no' answer to an entirely
   different question." Id. Changing "Jew" to "kike" may be
   as blatant a distortion as changing a "no" answer to a "yes,"
   so greatly does it alter the sense of the speaker's statement;
   if so, then the basic accuracy of the report is affected.
   Further, when the word chosen by the translator is an
   inflammatory term such as "kike," the licensee could be
   expected to assure itself of the accuracy of the translation; if
   it does not do so, the Commission may appropriately consider
   that fact in reaching a conclusion about the broadcaster's
   _______________________________
   * Counsel for the Commission was unable to say at oral argu
   ment whether the agency simply did not believe that such evidence
   could ever be probative--which would be a mistake--or understood
   the point we are making but chose to exclude such evidence for
   prudential reasons--which would be an exercise of judgment within
   its discretion if not unreasonable.
   intent to distort the news. The Commission was therefore
   unreasonable in dismissing this charge without an explana
   tion.
   We need not discuss here each of the other factual inaccu
   racies raised by Serafyn. On remand the Commission should
   consider whether any other error was sufficiently obvious and
   egregious to contribute to an inference about CBS's intent,
   and therefore to qualify as "extrinsic evidence."
   CONTENTS:
   Title Page
   I. Background
   II. News Distortion
   A. Evidentiary standard
   B. Licensee's policy on distortion
   C. Nature of particular evidence
   1. Extrinsic evidence
   (a) Outtakes of the interview with Rabbi Bleich
   (b) The viewer letters
   (c) The refusal to consult Professor Luciuk
   2. Evidence of factual inaccuracies
   D. Misrepresentation
   III. Conclusion
   D. Misrepresentation
   In Stockholders of CBS, Inc. Serafyn argued that CBS
   made a misrepresentation to the Commission by misleading
   WUSA about its treatment of the viewer letters and thereby
   causing the affiliate to transmit that erroneous information to
   the Commission. The Commission responded that "[m]isrep
   resentation is composed of two elements: a material false
   statement made to the Commission and an intent to make
   such a statement." 11 FCC Rcd at 3753. The Commission
   then held Serafyn had neither alleged that CBS had made its
   representation directly to the Commission nor "provided
   [any] evidence that CBS [had] intended to convey false infor
   mation to the Commission through its affiliate." Id.
   In reviewing the Commission's conclusion that CBS did not
   make a misrepresentation we ask only whether the Commis
   sion was "cognizant of the issue raised and, upon the record,
   reasonably resolve[d] that issue." WEBR, Inc. v. FCC, 420
   F.2d 158, 164 (D.C. Cir. 1969). In this case the answer to
   both questions is yes.
   There is no dispute that CBS did not make its false
   statement directly to the Commission. Serafyn argues, how
   ever, that directness has never been required, that "CBS was
   aware of Appellants' complaint against WUSA-TV," and that
   CBS's misrepresentations to WUSA therefore should "be
   taken as seriously as if made directly to the Commission."
   The Commission responds first that there is no evidence that
   CBS intended to make any misrepresentation--"the most
   that was shown in the record below was that one official of
   CBS was careless or negligent in providing information to
   [WUSA]"--and second that it will sanction only a misrepre
   sentation made directly to the Commission or intended to be
   passed on to the Commission.
   The Commission reasonably found Serafyn had not alleged
   that CBS intended to make any representation either directly
   or indirectly "to the Commission." Assuming for the sake of
   the argument that CBS could be sanctioned for making a
   misrepresentation through WUSA, we agree with the Com
   mission that Serafyn did not substantiate his claim that CBS
   knew about the complaint pending before the agency when it
   made the two misrepresentations to WUSA. Serafyn's only
   evidence is that the UACN had sent CBS's counsel a copy of
   the complaint, but that was after WUSA had received the
   misinformation and relayed it to the Commission. Absent
   any allegation that CBS knew that the first two versions of
   the incident it provided to WUSA would make their way to
   the Commission, the agency reasonably decided not to sanc
   tion CBS for misrepresentation.
   CONTENTS:
   Title Page
   I. Background
   II. News Distortion
   A. Evidentiary standard
   B. Licensee's policy on distortion
   C. Nature of particular evidence
   1. Extrinsic evidence
   (a) Outtakes of the interview with Rabbi Bleich
   (b) The viewer letters
   (c) The refusal to consult Professor Luciuk
   2. Evidence of factual inaccuracies
   D. Misrepresentation
   III. Conclusion
   III. Conclusion
   The Commission acted arbitrarily and capriciously in deny
   ing Serafyn's petition without analyzing more precisely the
   evidence he presented. On the other hand, the Commission
   reasonably held that CBS did not make a misrepresentation
   to the Commission. We therefore vacate and remand the
   Commission's decision in WGPR and affirm its decision in
   Stockholders of CBS Inc.
   So ordered.
   HOME DISINFORMATION 60 MINUTES 738 hits since 12Aug98
   Jeannine Aversa Associated Press 12Aug98 FCC must review 60 Minutes Segment
   Serafyn had asked the FCC to turn down CBS' license request for
   WGPR-TV in Detroit - now WWJ-TV - arguing that the network was not
   fit to receive the license because it had aired a distorted news program.
   The Associated Press article below provides a brief introduction to the
   full United States Court of Appeals decision which is available on the
   Ukrainian Archive. The original of the Associated Press article was
   provided by Yahoo, more specifically at Jeannine Aversa.
   Wednesday August 12 2:58 AM EDT
   FCC To Look at '60 Minutes' Segment
   JEANNINE AVERSA Associated Press Writer
   WASHINGTON (AP) - Responding to a federal appeals court decision,
   government TV regulators will take a new look at whether CBS' "60
   Minutes" intentionally distorted the news in a 1994 segment on the
   Ukraine.
   A Federal Communications Commission ruling against CBS on the matter
   could call into question the network's fitness to hold all or some of its
   broadcast licenses, said attorneys for the agency and for Alexander
   Serafyn, who led the court case against the "60 Minutes" report.
   But CBS attorneys, speaking on condition of anonymity, disagreed. They
   said only WWJ-TV in Detroit - the station involved in the present
   challenge - could be affected.
   On Tuesday the U.S. Court of Appeals for the District of Columbia
   concluded that the FCC didn't sufficiently explain why it decided not to
   hold a hearing on the allegations involving the "60 Minutes" segment.
   Given the court's ruling, the commission will re-examine the entire
   record, including Serafyn's allegations that the segment was
   intentionally distorted, an FCC attorney said.
   Serafyn had asked the FCC to turn down CBS' license request for WGPR-TV
   in Detroit - now WWJ-TV - arguing that the network was not fit to receive
   the license because it had aired a distorted news program.
   Serafyn, an American of Ukrainian ancestry who is retired and living in
   Detroit, had submitted evidence to the FCC involving his allegation about
   the broadcast, entitled, "The Ugly Face of Freedom." The FCC denied
   Serafyn's petition for a hearing, saying it would not investigate an
   allegation of news distortion without "substantial extrinsic evidence."
   The court said the FCC misapplied its standard for holding a hearing
   because it required Serafyn to demonstrate that CBS intended to distort
   the news rather than merely requiring that he "raise a substantial and
   material question of fact" - a less demanding test.
   CBS attorneys asserted there was no evidence the network intentionally
   distorted the segment. In addition, they said the FCC has never revoked
   a broadcast license on such grounds.
   The broadcast angered some viewers who believed that parts had been
   designed to give the impression that all Ukrainians harbor a strongly
   negative attitude toward Jews, the court said.
   "This is basically an effort on the part of the Ukrainian community,"
   said Arthur Belendiuk, Serafyn's attorney. "The case is not so much
   about Mr. Serafyn as it is about a community that felt horribly maligned
   by what was said."
   After the FCC revisits the case, the commission has several options: It
   could issue a new order that basically upholds its 1995 order but
   provides more details on how the decision was reached; it could order a
   hearing on the matter; or it could ask interested parties to comment and
   then it could issue a new order, the FCC attorney said.
   Whatever the commission ultimately decides is likely to be appealed by
   the losing party, Belendiuk and other attorneys said.
   HOME DISINFORMATION 60 MINUTES 1156 hits since 12May98
   Rabbi David H. Lincoln Ukrainian Weekly 30October94 A New York rabbi's response
   Rabbi David H. Lincoln of the Park Avenue Synagogue in New York was among the first to object to the 60 Minutes
   broadcast, The Ugly Face of Freedom of 23Oct94. Rabbi Lincoln has had a longstanding interest in Ukraine, inherited
   from his father, as is explained in the discussion of The Ukrainian Question in 1935.
   Everything below is from the Ukrainian Weekly.
   A New York rabbi's response
   Following is the text of a letter sent on October 25 to the CBS program "60 Minutes" by Rabbi David H. Lincoln of
   the Park Avenue Synagogue. The letter is reprinted here with the permission of Rabbi Lincoln, who last year traveled