Whether FCC staff seizure of Universal Service Fund funding via civil forfeiture is 'pure debt collection' under the Debt Collection Improvement Act of 1996

QUESTIONS PRESENTED 1. Whether FCC staff seizure of Universal Service Fund funding via civil forfeiture, a procedure unsupported by rulemaking, is “pure debt collection” under the Debt Collection Improvement Act of 1996, Slip Op. App. 21, where the Record shows no outstanding Federal debt and where other circuit courts hold that: the DCIA does not authorize agency debt adjudication; the FCC cannot seize USF funding; the FCC is not directly involved in USF administration; and the USF contains no Federal funds. 2. Whether civil forfeiture is punitive and time barred, Kokesh v. SEC, 187 S. Ct. 1635 (2017); Liu v. SEC, 140 S. Ct. 1936 (2020), when it is undisputed that: the Record shows no outstanding Federal debt; the forfeiture serves multiple law enforcement purposes; excessive financial penalties beyond the purported debt are collected; and the forfeiture exceeds profits. 3. Whether deference to a civil forfeiture which fails to specify a legislative rule prohibition, Slip Op. App. 36, 37 n.17 is proper where the forfeiture order furthers False Claims Act litigation and where uniform appellate precedent holds that deference in rule adjudications denies fair notice.