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"We are definitely happy with your firm's services. It is as if you are an internal department of our company to whom we refer all telecom-related matters."
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"We hired Jonathan to represent our telecommunications licensing needs. At the time we were a start-up company with only a small amount of investment revenue. Attorney costs could have been enough to rethink the business plan. Jonathan worked with us on a payment plan basis which allowed us to focus on getting customers while he worked on getting us our licenses. He provided introductions to companies we eventually hired to assist us with tax issues and other FCC requirements. When we were interested in selling our company Jonathan made introductions to other telecom companies that were in the market for our type of company. He managed the contract process at every level through the acquisition. The best recommendation I can give is that when I go to do this again I will hire Jonathan."
"Jonathan is well-versed in a broad range of telecom regulatory matters. He uses his expertise to arrive at innovative, real-world business solutions while maintaining a high degree of professionalism."
"Jonathan is extremely knowledgeable in his field. He has provided invaluable telecom expertise to us and our subsidiary company on countless occasions. We would be lost without him. I highly recommend Jonathan!"
"Jonathan['s firm] was able to provide our ISP association with fresh responses to the RBOC FCC petitions as opposed to the boilerplate comments most law firms offered. Jonathan has a good understanding of the industry and how things work at the FCC."
—COO of a leading virtual
system company
—President of US operating
unit of foreign PTT
—CEO and Founder of a
nationwide Hosted
VoIP provider
—Senior Director of Telecom
of US operating unit
of international multi-media
conglomerate
—President & CEO of
regional CLEC
—Founder/CEO of enhanced
international communications carrier
—Controller of leading
provider of long distance,
wireless, point-of-sale and
carrier services
—Founder/CEO of
regional CLEC
—Vice President of
leading provider of
long distance, wireless,
point-of-sale and carrier
services
—CFO of enhanced
conferencing solutions
provider
—Member, Federation of
Internet Solutions Providers
of the Americas
Contact Information

Marashlian & Donahue, LLC

The CommLaw Group
1420 Spring Hill Road
Suite 401
McLean, Virginia 22102

Telephone: (703) 714-1300
Facsimile: (703) 714-1330

E-mail: mail@commlawgroup.com

News and Information
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Network Outage Reporting Requirements Extended to Interconnected VoIP

On February 15, 2012, the Federal Communications Commission (“FCC”) adopted an order requiring Interconnected VoIP service providers to report significant network outages that meet specific criteria and thresholds. 

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FCC Adopts New Rules for Telemarketing Robocalls

In response to the high volume of complaints over unwanted robocalls, the Federal Communications Commission (“FCC”) on February 15, 2011 issued changes to its rules for autodialed or prerecorded telemarketing calls made to wireline and wireless phones.

Under the new rules, consumers must give their express written consent before receiving a robocall.  The “established business relationship” exemption to the new consent requirement was further eliminated.  Telemarketers will also have to provide an automated interactive opt-out mechanism during robocalls so that consumers can immediately tell telemarketers to stop calling.  Finally, a limitation was adopted on the number of abandoned or “dead air” calls telemarketers can make during a calling campaign.

A copy of the FCC’s Report and Order is linked here.

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FCC Considers Expanding Outage Reporting to I-VoIP and Broadband; Restrictive Robocall Rules also on Tap
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Conferencing Provider Asks FCC to Reverse USAC Refusal to Offset Duplicate USF Contributions

Good faith efforts to comply with the directives of the Universal Service Administrative Company (“USAC”) were punished yet again as disclosed in a recent Petition for Review filed with the Federal Communications Commission (“FCC”).  InComm Solutions, Inc. (“InComm”), a provider of call-bridging services, is appealing USAC’s decision to deny its request to offset over $250,000 in USF contribution payments paid by InComm to its supplier, Sprint, during a period in which InComm concedes it was not in compliance with FCC rules requiring call-bridging providers to directly contribute. 

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Providers Urge FCC to Resolve Uncertainties Surrounding Applicability of USF to MPLS Services

On February 6, 2012, representatives of the following Multi-Protocol Label Switching ("MPLS") service providers: Verizon, BT Americas, XO Communications, Orange Business Services and NTT America ("MPLS Providers"), met with staff of the Federal Communications Commission's ("FCC") Wireline Competition Bureau.  At the meeting, the MPLS Providers discussed the urgent need for the FCC to resolve legal uncertainties regarding the applicability of Universal Service Fund fees and requirements to MPLS Services.    

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USAC Prepares to Expand and Intensify Audits of USF Participants

On February 1, 2012, the Universal Service Administrative Company (“USAC”) submitted the federal Universal Service Support Mechanisms fund size and administrative cost projections for the second quarter of calendar year 2012 (2Q2012), in accordance with Federal Communications Commission (“FCC”) rules. The 2Q2012 report details steps taken by USAC during the past two years to beef up its audit capabilities, budget and resources in response to FCC directives. On its face, the 2Q2012 report indicates that the industry – both on the USF recipient and contribution side – can expect an active and aggressive year of USAC enforcement ahead.

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Rural Telcos Lobby FCC to Expand Contributor Base as Part of USF Contribution Reform

With last year's reforms to the Intercarrier Compensation regime and Universal Service Fund (“USF”) distribution system, moves which clearly shifted the policy focus from the switched telephone network of today to the Broadband networks of tomorrow, the Federal Communications Commission (“FCC”) now stands poised to tackle the sticky issue of how to pay for these reforms. Although the FCC has yet to announce the much-anticipated USF Contribution Reform Notice of Proposed Rulemaking (“NPRM”), powerful lobbies are already hard at work seeking to influence the Commission; none has been more active than the National Telecommunications Cooperative Association (“NTCA”), a trade group representing the interests of rural, independent telephone companies.

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The CommLaw Group to Exhibit at IT EXPO

Representatives of The CommLaw Group and its regulatory compliance consulting and administration affiliate, The Commpliance Group, will be exhibiting at the Internet Telephony Expo (IT EXPO East) in Miami, FL from February 1 – 3. 

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FCC Form 499-Q (4th Quarter) Is Due February 1st
Reminder, the deadline for filing FCC Form 499-Q with the Universal Service Administrative Company ("USAC") for the Fourth Quarter is February 1st. All non de minimis providers of telecommunications services and interconnected VoIP services are required to complete Form 499-Q and report actual revenue data for the Fourth Quarter of the following year (October 1st - December 31st) and projected revenue for the Second Quarter of next year  (April 1st - June 30th).
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Comment Cycle Established for Twenty-First Century Communications and Video Accessibility Act FNPRM

On October 7, 2011, the Federal Communications Commission (“FCC”) adopted a Report and Order implementing certain provisions of the Twenty-First Century Communications and Video Accessibility Act of 2010 (“CVAA”).  The CVAA was enacted to ensure that people with disabilities have access to the modern and innovative communications technologies of the 21st century.  The FCC also released an accompanying Further Notice of Proposed Rulemaking (“FNPRM”) that seeks comment on outstanding issues regarding the implementation of the CVAA. 

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