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High Severity

License Revocation Without Clear Standards

This provision allows the Division to recommend license suspension or revocation for publishers who become "notorious for publishing false or other information" after just one compliance warning (72(1)(c)). The term "notorious" is undefined and subjective—lacking criteria for how many publications, over what timeframe, or what types of violations trigger this status. This creates a shortcut around the graduated enforcement model requiring three warnings (72(1)(a)), enabling the Division to target publishers through vague standards. License revocation is an extreme prior restraint that eliminates a publisher's ability to operate, yet the provision lacks proportionality safeguards and doesn't reference defenses available elsewhere in the bill (quick correction, public interest). Combined with 73's Cease and Desist orders requiring no prior warning, this creates severe chilling effects on investigative journalism and government criticism.