The phone notification rule applies whether the person's voice is being put on the air live, or taped for later broadcast - or whether, as in the case of WNOV, Milwaukee, a broadcaster calls someone's mobile phone and airs their "answer" message. That's going to cost WNOV a $4,000 fine, and the Commission hopes it serves as a reminder of the longstanding regulation. WNOV argued that last year's incident occurred while an "independent contractor" was on the air. But the FCC always holds the licensee responsible, no matter what kind of arrangements they make for programming. Read the FCC's Notice of Apparent Liability here.