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Client Advisories

Keep up with legal & regulatory developments impacting your business.

Thanks to Congress, the future of CPNI looks much like its past >

August 14, 2017

How outdated FCC privacy regulations are here to stay

Not too long ago, Customer Proprietary Network Information (CPNI) rules were slated for elimination. When the Federal Communications Commission under Chairman Tom Wheeler adopted new privacy rules late last year, the FCC planned to phase out existing CPNI-specific rules, such as the annual...Continue Reading »

Call to Action: Don't Let Them Take Away Your 3.5 GHz Spectrum! Tell the FCC "NO" by August 8! >

August 2, 2017

As discussed in a previous post, T-Mobile USA, Inc. ("T-Mobile") is petitioning the FCC to gut the core purpose of the current rules governing the 3550-3700 MHz spectrum band ("3.5 GHz" band), which is to lower the barrier of entry of smaller carriers into the wireless 5G business by   allowing commercial shared use of 3.5 GHz via licensed and...Continue Reading »

Calling Platform Providers Put on Notice of TCPA Liability with $2.9 Million Fine >

July 18, 2017

Keep Track of TCPA Developments at the FCC by Downloading Our 

July 2017 TCPA Compliance Monitoring Report

In what is surely a troubling event for calling platform providers, the FCC last week announced a nearly $2.9 Million forfeiture against the operator of a dialing platform for making unauthorized “robocalls” to mobile telephone numbers...Continue Reading »

USAC Expected to Audit Eligible Telecommunications Carriers for Fraud and Abuse >

July 18, 2017

Audits Could Carry Severe Penalties; Seek Legal Counsel if Your Company is Audited


Last week, Federal Communications Commission (FCC) Chairman Ajit Pai issued a set of instructions to the Universal Service Administrative Company (USAC) to clamp down on waste, fraud, and abuse in the universal service system.  The instructions seek to end...Continue Reading »

FCC Reinstates CPNI Compliance Rules - What You Need to Know >

July 3, 2017

On the eve of the 4th of July Holiday weekend, the Federal Communications Commission ("FCC") released an Order ("FCC Privacy Order") dismissing, as moot, 11 petitions seeking reconsideration of Obama Era Broadband Privacy Rules, and reinstating the CPNI Regulations that existed prior to the FCC's foray into regulating broadband under Title II. ...Continue Reading »

2.289% TRS Contribution Factor May Exceed Amount You Collected via Cost Recovery Surcharge - What Should Your Company Do Now? >

July 3, 2017

In a June 30th Order, the FCC adopted a 2.289% TRS Contribution Fee Factor ("TRS Fee Factor") covering the 2017-2018 funding year.  The 2.289% TRS Fee Factor marks a significant (nearly a full half percent) year-over-year increase from the prior TRS Fee Factor of 1.862%.  For reasons explained below, new TRS Fee Factor may end up requiring some...Continue Reading »

FCC Updates Equipment Authorization Rules >

July 3, 2017

In its July 2017 Open Meeting, the Federal Communications Commission (“FCC”) will vote on a Report and Order ("R&O")  containing new rules that will impact how RF equipment manufacturers, vendors, importers, and distributors may conduct their businesses.  The FCC emphasized the importance of the new regulations on the RF equipment industry,...Continue Reading »

FCC Sets Comment Deadlines on Broadband Access to MTEs Inquiry >

June 26, 2017

Concerned that its current policies on contractual and non-contractual arrangements between service providers and owners/managers of commercial multiple tenant environments (“MTEs”  such as apartment buildings, condominiums, shopping malls, etc.) might be hindering deployment of broadband deployment to those multi-unit premises, the Federal...Continue Reading »

Adrian Abramovich and the Terrible, Horrible, No Good, Very Bad Day (Thanks to the TCPA) >

June 26, 2017

Keep Track of TCPA Developments at the FCC by Downloading Our 

June 2017 TCPA Compliance Monitoring Report

For anyone who thought the Federal Communications Commission’s (“FCC” or “Commission”) new Chairman would put an end to eye-popping proposed forfeitures, think again. That’s especially true for forfeitures related to the Telephone...Continue Reading »

T-Mobile to FCC: “Let’s License the Entire 3.5 GHz Band!” >

June 25, 2017

In a last-minute attempt to eviscerate the core purpose of the rules governing the 3550-3700 MHz spectrum band (“3.5 GHz” band), T-Mobile USA, Inc. (“T-Mobile”) recently filed a Petition for Rulemaking (“Petition”), proposing that the FCC license the entire spectrum band and grant other favors to large wireless carriers.  If adopted, T-Mobile’s...Continue Reading »

New Chief of FCC Enforcement Bureau Likely Signals Continued De-Politicization and Return to Strict Application of Law >

June 22, 2017

On June 21, 2017, FCC Chairman, Ajit Pai, announced his decision to tap Rosemary Harold to lead the FCC’s Enforcement Bureau.  Ms. Harold has been a partner with the law firm Wilkinson Barker Knauer since 2011 and is best known for her media experience.  Prior to joining Wilkinson, Ms. Harold served as a legal advisor to FCC Commissioner Robert...Continue Reading »

Website Linked to Physical Store Must Be Accessible to Visually Impaired Customers >

June 22, 2017

On June 12, 2017, the U.S. District Court for the Southern District of Florida decided the case of Gil v. Winn-Dixie Stores, Inc. in favor of Plaintiff; awarded attorney fees and entered an injunction against the grocery chain.  The court ruled that a Winn-Dixie website that was tightly linked to its physical store locations must be accessible to...Continue Reading »

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