The FCC releases statistics from last year's third quarter, and they show 139 complaints in July, 97 in August, and 302 in September. That's in contrast to the tens of thousands of emails received by the Commission in the years immediately following the 2004 Janet Jackson Super Bowl incident. Bono, Cher and Nicole Richie all had "fleeting expletives" on live TV awards shows, and radio personalities from Mancow Muller and Howard Stern to Bubba the Love Sponge were the subjects of complaints and sometimes fines. The Commission hasn’t issued any new fines in years, especially against radio. That's probably because of the uncertain legal situation, which may gain some clarity after the Supreme Court's expected decision in the ABC and Fox cases later this year. Radio could find itself under fire again from the Commission. Note that indecency and obscenity are different things under the FCC's policy, and that there is a "safe harbor" for indecency after 10pm at night.