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The FCC had received complaints about Howard Stern as early as , but its limited power at the time prevented further action taking place. The FCC broadened its guidelines in following an investigation over indecencies broadcast on the show. In , Infinity Broadcasting , owner of Stern's flagship station WXRK and some of his syndication affiliates, was issued its first fine. Stern announced his departure from "terrestrial" radio to begin a five-year contract with Sirius Satellite Radio , a subscription-based satellite radio service not subjected to the FCC's broadcast obscenity rules. In , the United States Supreme Court upheld the FCC's authority to fine broadcasts for indecent programming at hours when children could be listening.

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