In the Spring of 2009, then-Citadel-owned WLS ran a variety of programming supplied by Workers Independent News: 45 90" spots, 27 :15 promotional announcements, two 2-hour programs, and a single 1-hour program. The FCC determines that WLS failed to satisfy its sponsor identification requirements for 11 of the 90" spots, and is fining WLS the baseline $4,000 for each of them. The subject of the WIN campaign was to create support for the Illinois legislature to use available federal stimulus money to fix up the infrastructure. Attorney David Oxenford of Davis Wright Tremaine writes on BroadcastLawBlog that "This case seems to impose a very high penalty for a limited number of violations. The announcement arguably let people know that WIN was involved with the production of the spot, even if it did not explicitly say that they had paid for the airtime." Oxenford says the warning for other broadcasters is that "stations need to be especially careful in any sort of paid programming dealing with controversial issues." The FCC has already been vocal on the subject of "VNRs" aired by some television stations, referring to Video News releases that appear to be news, but are in fact supplied by an outside source without sufficient sponsor ID. The FCC is currently considering a rulemaking about  sponsor ID, defined as the exchange of consideration for airtime.