» Jonathan S. Marashlian

Managing Partner

1420 Spring Hill Road
Suite 401
McLean, Virginia 22102

703.714.1313 (telephone)
703.714.1330 (fax)

» jsm@commlawgroup.com
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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.

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Representative Experience

• 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

Publications

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, “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, "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:
  • “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 dozens of articles for The Prepaid Press (www.Prepaid-Press.com), including:
  • "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