Firm News
- In recent years, the Firm has represented several long distance resellers in connection with slamming enforcement investigations before the FCC. Of more than thirty slamming penalties assessed by the FCC's Enforcement Bureau since 1999, the Firm has the distinction of having secured, on behalf of two clients, the two lowest FCC Consent Decree settlement amounts.
- In August 2009, the Firm was successful in securing the cancellation of a Notice of Apparent Liability in connection with an alleged Customer Proprietary Network Information (CPNI) violation before the FCC in the amount of $20,000. Not only did this result avert a potential FCC forfeiture assessment, but it also avoided a settlement or consent decree which potentially could have imposed compliance conditions upon the company.
- In August 2009, the Firm successfully prosecuted an appeal with the Universal Service Administrative Company (USAC) of its ruling which would have required a service provider to immediately pay hundreds of thousands of dollars in Universal Service Fund (USF) assessments based upon information which the provider erroneously entered into a USF remittance form (called an "FCC Form 499-A"). This USAC reversal essentially enabled the service provider to realize an immediate and substantial savings.
- In September 2008, the Firm responded to nearly thirty letters of inquiry from the FCC concerning alleged violations of Customer Proprietary Network Information (CPNI) rules. These responses enabled approximately 50% of the firm's respondents to avoid being cited in the FCC's Omnibus Notice of Apparent Liability regarding CPNI violations (sanctioning over 600 providers) which was released in February 2009.
- The Firm responded to an FCC letter of inquiry concerning an alleged unauthorized transfer of control of a telecommunications carrier's international (or Section 214) authorization in apparent violation of the FCC's rules. The response helped successfully persuade the FCC's Enforcement Bureau against initiating further enforcement action against the carrier, thereby avoiding potential monetary penalties for alleged rule violations.
- Mr. Crowe was quoted in 2009 in an article about one-way end user agreements published in the Telecom Association's newsletter.
- We are pleased to announce that, effective January 1, 2009, Cheng Liu became a Partner with the Firm.
- The Firm recently counseled a major interactive telecommunications services provider with respect to structuring its interactive phone-based service in order that it can permissibly operate within the exemptions provided under FCC and state public utilities commission telecommunications regulations.
- In recent years, the Firm has filed numerous applications with the FCC regarding corporate reorganizations, mergers, asset acquisitions and other related transfers of control/assignments. In connection with these applications, the Firm has obtained consent from the FCC for clients to consummate transactions, brought clients who failed to timely obtain FCC approval into regulatory compliance, and obtained special temporary authorizations for clients which were operating outside of their authority. In the course of this process, the Firm has negotiated agreements with the Executive Branch resolving potential concerns with such acquisitions.
- In the past, the Firm counseled a large service provider owned by a South American government in relation to efforts to negotiate a free trade agreement with the U.S. and to better understand the specific legal and regulatory requirements of the U.S. market.
- On behalf of a large corporate end user, the Firm simultaneously negotiated three interexchange and international service provider agreements and one local service provider agreement, while advising the client on a successful migration from, and termination of, the services it had been receiving from a major U.S. carrier which had entered into Chapter 11 bankruptcy.