Legal counsel to the Telecommunications, Voice over IP (VoIP) / SIP, Cloud Communications and Broadband industries; experienced in virtually all aspects of federal and state communications law and regulation. Serving clients in these industry segments:
- Cloud Communications and providers of Software as a Service ("SaaS") / Communications as a Software ("CaaS")
- Traditional wireline telecommunications services, including domestic & international Long Distance (IXC) and Competitive Local Exchange (CLEC)
- Information & enhanced communications services
- Wireless and MVNO services
- All segments of prepaid services, including Prepaid Calling Cards, PINless, Wireless/MVNO, Gift Cards and Financial Services
- Broadband networks, ISPs & Internet Access services
- Advanced communication application (apps) services & developers
- Broad spectrum of Internet Based (IP-based) services, including Voice over Internet ("VoIP") and other hybrid & convergent communications service providers
- Communications equipment manufacturers
Specialized experiences include: Federal Communications Commission (FCC), Universal Service Administrative Company (USAC), Federal Trade Commission (FTC), and nationwide state utility commission (PUC), Secretary of State and Attorney General regulatory, transactional, enforcement defense and FCC advocacy services; telecom tax issues, including traditional communications taxes, VoIP, SIP and Cloud-communications taxes, Universal Service Fund (USF) and other regulatory fees & tax planning; wireline & wireless transfers/assignments of control; mergers, acquisitions and customer base/asset sales; regulatory compliance & reporting, contract drafting, negotiations and review; domestic and international communications market entry services, including licensing & tariffing; dispute resolution and administrative litigation; FCC advocacy and representation of clients in a variety of administrative proceedings, including rulemakings, declaratory petitions, and enforcement matters, such as Show Cause, NALs and informal and formal complaints.
As the firm’s Managing Partner and head of its Regulatory and Communications Taxes and Fees Practices, Mr. Marashlian is responsible for coordinating and managing staff and attorneys and guiding the firm's clients through the maze of state and federal regulatory requirements, including the coordination, management and execution of regulatory filings associated with a full range of corporate and regulatory transactions, from the routine to the highly complex. Mr. Marashlian assists clients with regulatory compliance, transactional, litigation & regulatory defense matters before the FCC, USAC and state regulatory agencies across the nation; counsel clients in all aspects of state and federal regulatory matters with concentrations in the areas of telecommunications taxes, regulatory fees, and the prosecutions and defense of actions before the FCC Enforcement Bureau, State Public Utility Commissions and other government agencies.
Mr. Marashlian has applied his extensive knowledge of the telecommunications and information & advanced communication technology industries to assist clients with regulatory compliance, transactional, litigation & regulatory defense matters before the FCC and other federal agencies, as well as state regulatory agencies across the nation. Mr. Marashlian counsels clients in all aspects of state and federal regulatory matters as well as the impact regulation and operating in an incumbent dominated industry have on competitive businesses of all sizes, from start-ups to established providers.
Mr. Marashlian is experienced with a broad range of telecom issues – including long distance, competitive local exchange, international, VoIP, IP-enabled and other advanced communications and information services, Internet access, prepaid communications, wireless, satellite and more. He is well acquainted with the Telecommunications Act of 1996, the FCC's interpretation and implementation of the Act and the many legal issues and battles that have arisen from the Act.
Mr. Marashlian's expertise extends beyond traditional voice technologies and includes knowledge of convergent technologies, such as VoIP, xDSL, the myriad of IP-enabled services and technologies and other issues surrounding the Internet and high technology. In 1999, the Multimedia Telecommunications Association certified Mr. Marashlian as a Convergent Network Technologies Specialist.
During law school, Mr. Marashlian joined the National Telecommunications Cooperative Association ("NTCA") and worked in its Legal and Industry Affairs Division. While at NTCA, he analyzed and interpreted Federal Communications Commission orders and court decisions affecting rural telcos and researched and prepared comments and other filings concerning the interpretation and implementation of the Telecommunications Act of 1996.
Mr. Marashlian also worked in the Local Markets and Enforcement Group of MCI Communication Corp.'s ("MCI") Federal Law and Public Policy Division. During his tenure at MCI, Mr. Marashlian analyzed FCC decisions bearing on local competition, evaluated and responded to Section 253 preemption petitions, and assisted MCI's efforts to gain entry into the local exchange market.
- The Commpliance Group, Inc.
Oversee and set strategic vision of firm’s affiliated regulatory compliance consulting firm.
- My FCC Compliance
Created revolutionary, one-of-a-kind service that puts the power to obtain basic FCC licenses and maintain compliance with FCC regulations directly in the hands of communications service providers.
- Ad Hoc Coalition of International Telecommunications Companies
Coalition founder and advocate for fair, equitable and responsible administration of Universal Service Fund program by Universal Service Administrative Company.
- Member, Editorial Advisory Board for the Thompson Multichannel Video Compliance Guide
- Represent competitive telecommunications, enhanced services, interconnected Voice over IP (VoIP), non-Interconnected VoIP, Cloud communications and Software as a Service (SaaS) providers in all matters before the FCC, USAC and state regulatory agencies across the nation;
- Counsel clients on regulatory requirements and compliance obligations arising under the federal Telecommunications Act, FCC Regulations and State Public Utility Commission rules and policies;
- Regularly engage in regulatory litigation and mediation before the FCC and state agencies regarding commercial disputes, regulatory compliance, competitive harms, marketing practices and more;
- Participate in Rulemaking, Declaratory Ruling and other policy proceedings and engage in lobbying and policy/client advocacy before the FCC;
- Obtain FCC and state authorizations for local, long distance, international, operator and pre-paid telecom services; drafting, preparing, filing and maintaining telecommunications tariffs; advising clients on state and federal regulatory developments; cultivating close working relationships with FCC and state commission staff to aid client interests;
- Manage the prosecution of routine and complex regulatory filings associated with the full panoply of corporate transactions, including: transfers of control and assignments of authorization, FCC 214 discontinuances, and asset and customer base transfers;
- Spectrum license assignment, partitioning, and transfers of control applications utilizing Universal Licensing System;
- Expert in state and federal rules regarding slamming, cramming and telemarketing;
- Negotiate settlements of carrier contractual and billing disputes, including FCC mediations;
- Lead regulatory counsel to facilities-based IXC, Touch America, Inc. ("TA"); represented TA during its acquisition of the in-region long distance assets of Qwest Communications International, Inc. ("Qwest") and subsequent corporate re-organization and divestiture of The Montana Power Company; prosecuted two formal FCC Complaints against Qwest; assisted FCC’s Investigations & Hearings Division in its informal investigation of Qwest (File No. EB-02-IH-0674), which at the time resulted in the single, largest FCC fine ever issued;
- Represented regional ISP association, Federation of Internet Service Providers of America (FISPA), against BellSouth and Verizon de-regulation of telecommunications component of wireline broadband;
- Regulatory counsel to Nortel Networks and guide roll-out of Enterprise Division’s Hosted Solutions
- Telecommunications, VoIP, and Advanced Communications Services
- Communications Taxes and Fees
- USAC Compliance, Audit Preparation and Defense
- Broadband Networks and Internet Applications
- Internet Law & E-Commerce
- Wireless Communications and MVNOs
- Information Privacy, Data Security and Consumer Protection
- International Telecommunications
- Telemarketing & Mass Market Sales
- Corporate, Contracts and Commercial Transactions
- Dispute Resolution and Litigation
- Debit Cards, Gift Cards and Stored Value
- Satellite: Land Mobile, Marine and Aero
- Cloud Computing and Communications (SaaS / CaaS / IaaS)
- Internet of Things & Connected Devices
Mr. Marashlian is published in the Federal Communications Law Journal, and more recently, the CommLaw Conspectus. Mr. Marashlian actively contributes articles to industry and trade publications and is frequently quoted as an industry expert on a variety of subject matters.
- Co-Authored, "Confusion, Uncertainty, and Fear: How the FCC’s Increased Reliance on Adjudication Is Harming Carriers, Competition, Consumers, and Investment," Federal Communications Law Journal, Volume 68, Issue 2, August 2016
- Co-Authored, “Mis-Administration and Misadventures of the Universal Service Fund: A Case Study in the Importance of the Administrative Procedure Act to Government Agency Rulemaking,” CommLaw Conspectus, Journal of Communications Law and Policy, Volume 20, Issue 1, June 2011
- Co-Authored, "Detariffing and the Death of the Filed Tariff Doctrine: De-Regulation in the "Self" Interest," Federal Communications Law Journal, Volume 54, March 2002
- Co-Authored, "United States - International Telecommunications Law, 2nd Edition"
- Co-Authored, "Analyzing SIPs Role in Regulatory and Tax Structures," Internet Telephony, Nov. 1, 2011
- Authored, “The Future of VoIP: Regulatory Storm Clouds on the Horizon,” Internet Telephony, Oct. 2011
- Authored, “Do Taxes Really Matter? Navigating Regulatory Considerations Associated with the Transition to VoIP, SIP and Beyond,” VoIP Logic Quarterly, Sept. 2011
- Authored articles for Wireless Dealer Magazine, including:
- "Top 4 Wireless Providers Agree to Text-to-911 Commitments"
- "911 Regulations Evolving to Eliminate Loopholes and Exemptions for Prepaid"
- “FCC Considering Extension of USF Contributions to Wireless Text Messaging Services” (Oct. 2011)
- “FCC Signals Heavier Regulation of Private Label Distribution of Prepaid Wireless Services” (Sept. 2011)
- “FCC Considers Reform of the Federal Universal Service Low-Income Program” (Dec. 2011)
- Authored, "VoIP Service Provider Primer: Compliance with Communications Taxes and Regulatory Fees, 3-part series," TMCnet.com, November 2009
- Quoted, TMC Net, “FCC Considers Petition that Could Impact VoIP Peering Rules,” Paula Bernier, April 2011
- Quoted, Channelpro, “Using VPN for VoIP Security.” Martin Sinderman, January 2011
- Quoted, TMC Net NGN, “Broadband Stimulus Applicants Hold On for a Long, Bumpy Ride,” Paula Bernier, Sept/Oct 2009 | Volume 1/Number 5
- Quoted, Rural Telecommunications, "The Fight to Protect CPNI," Anna Henry, November 2009
- Interview, Network IP Connections, Regulatory Watch: Q&A with Jonathan Marashlian, Summer 2009
- Authored articles for The Prepaid Press (www.Prepaid-Press.com), including:
- "FCC Not the Only Enforcer", August 2014
- "Coalition Seeks Support to Lower TRS Fees", June 2014
- "Ad Hoc Coalition Wants Amnesty", May 2014
- "FCC to Clarify Scope of TCPA", March 2014
- "FCC Enforcement Sends Signals to Prepaid Wireless Providers", February 2014
- "USF Exemption Process, Confusion Starts January 1", Oct. 2013
- "Universal Service Fund Contributor Audits", August 2013
- "Hands off VoIP!," August 2006
- "Net Neutrality: What is it and why should I care?," June 2006
- "Year of the DAC," December 2005
- "Are Wireless Providers Destined for State Regulation?," June 2005
- "Misery Loves Company AT&T Calling Card Saga Continues," May 2005
- "Cutting the Cord Wireless boom causing states to rethink "hands off" approach to wireless regulation," March 2005
- "FCC Rules Against AT&T Order May Impact All Card Providers," March 2005
- "FCC USF Enforcement – Is the sleeping lion about to wake?," June 2004
- Co-Authored, "USTA v. FCC: A Decision Ripe for the Supremes," March 2004
- Co-Authored, "The Forgotten Quo," Phone + Magazine, May 2004
- Authored Articles for Accelerate Telecom Magazine ("ATM"), "LD Gets Hammered," Fall Quarterly 2001: "Uneven Playing Field," Winter Quarterly 2001
- Authored, "Preventing Re-Monopolization: A Call to Arms to Competitors" and "Telecom Re-Monopolization – Is it Too Late?," published on www.ISP-Planet.com and www.CLEC-Planet.com, 2001
- Co-Authored, "Operating in the Detariffed Environment: Are you Ready?," Phone + Magazine, August 2001
Mr. Marashlian received his Bachelor of Arts degree and graduated cum laude from the University of Richmond, majoring in Political Science. Mr. Marashlian earned his Juris Doctor at the George Mason University School of Law where he completed specialized courses as part of the law school's Regulatory Track; focusing on the telecommunications and information technology industries.
Mr. Marashlian is licensed to practice in the state of Maryland.
Admitted to United States Court of Appeals for the District of Columbia Circuit.
Member of the Federal Communications Bar Association since 1997 and Armenian Bar Association.
Mr. Marashlian has also been invited to speak at a variety of industry events:
- "Surviving a USAC Audit: Tips for Facing an Audit with Confidence," Speaker at TeleStrategies 2014.
- "Enter the SIP / Mobility / UCaaS Market with Confidence," Speaker at Cloud Channel Partners 2015.
- "Ask a Lawyer," Speaker at TeleStrategies 2015.
- "Managing Exemptions and Minimizing Exposure," Speaker at TeleStrategies 2013.
- “Advanced FCC Revenue Reporting: Misperceptions, Mistakes & Missed Opportunities,” Speaker at TeleStrategies 2012. Click here to download presentation.
- Cloud Communications Alliance Webinar on Federal, State and Local Laws that affect Hosted VoIP Products and Services, 2012.
- “Regulatory Landscape: FCC Regulation of Non-Interconnected VoIP Service and the ‘Cloud,’” Speaker at Polycom ITSP Leadership Summit (Dec. 2011). Click here to download presentation.
- “Regulatory Landscape: VoIP and Cloud-based Communications,” Speaker at Avaya Global Law and Contracting Conference (Nov. 2011)
- “Regulatory, Tax and Business Implications of Recent FCC Decisions Related to Enhanced Communications,” Speaker at TeleStrategies Communications Taxation 2011 (May 2011). Click here to download presentation.
- VoIP Taxation and Regulatory Fees on the Rise: Your Guide to Compliance, Thompson Interactive Audio Conference (August 2009)
- “The Future of Regulation, Taxes and Litigation in Prepaid Calling,” Speaker at Prepaid Press Expo (August 2008)
- “Prepaid Industry Legal & Regulatory Update,” Speaker at NetworkIP 2007 Prepaid Leadership Summit (September 2007)
- Sonus Networks Technical Leadership Forum 2007, Moderator of Panel Session on Today's Regulatory Environment & Net Neutrality
- “Prepaid Industry Legal & Regulatory Update: The Times, They are a Changin’,” Speaker at NetworkIP 2007 Prepaid Leadership Summit (April 2007)
- “Universal Service Fund: What is the End Game?,” Speaker at NetworkIP 2006 Prepaid Leadership Summit (September 2006)
- “USF: Past, Present & Future,” Speaker before National Telecommunications Credit Association (Nov. 2003)
- Implementation of the New National Broadband Plan – Issues, Opportunities and Challenges, Thompson Interactive Webinar (June 2010).
Winner - SmartCEO Executive Management Award
Winner – Telecommunications Law – International -- Lexology/International Law Office - (profiled at Page 124):
Winner – Telecommunications Law – US/Canada -- Lexology/International Law Office (profiled at Page 91):
Lexology/International Law Office Award Press Release:
Martindale-Hubbell. AV Preeminent Peer Rating (Jonathan Marashlian):
Martindale-Hubbell. Preeminent Client Rating (Jonathan Marashlian):
Lexology / International Law Office
Lexology / International Law Office