Practice Areas The Law Offices of Thomas K. Crowe, P.C. provides a broad range of legal services covering regulatory and compliance matters, commercial/transactional matters, litigation, lobbying/legislative representation and other specialized services.  The Firm represents a wide variety of clients, including IP telephony or VoIP providers, wireless service providers, facilities-based long distance providers and resellers, prepaid services providers, competitive local exchange carriers, and trade associations.  We have also represented government entities, including a public utilities commission, the Governors of two U.S. territories, and a government-owned service provider in South America.  Some of the areas in which we offer specialized legal services include the following:   Regulatory/Compliance Federal/State Policy Representation Wireless VoIP/Prepaid/Internet Information Services Commercial Transactions Litigation End User Legislative International     Regulatory/Compliance   Aiding both start-ups and established providers, the Firm offers comprehensive regulatory and compliance services before the FCC and each of the state public utilities commissions. Routine certification and licensing work is typically handled by one or more attorney-supervised regulatory specialists ensuring legally sufficient filings at very competitive (usually flat) rates. Should enforcement matters arise, competitors contest filings or other non-routine issues arise, immediate involvement by experienced telecommunications attorneys facilitates the best possible outcome. Beyond the entry phase, the Firm routinely assists its clients with varied compliance filings and enforcement matters at both the federal and state levels. Services offered include: FCC Section 214 filings and preparation of FCC required Price Lists (offered at competitive fixed rates). Universal Service compliance, including 499A and 499Q submissions, USF disputes with the FCC and USAC, contribution minimization counseling and registered agent services (fixed rates available). Customer data (Customer Proprietary Network Information or CPNI) compliance and filing requirements (CPNI plans available at fixed rates).  Communications Assistance for Law Enforcement Act (CALEA) counseling and compliance.  CALEA Compliance Plans filed with the FCC at fixed rates.    VoIP regulatory compliance, including FCC 499 filings. State certification filings and tariff preparation (prepared at competitive flat rates).  Payphone compensation (DAC) compliance and protests. "Slamming" enforcement matters before the FCC and state commissions (including enforcement investigations and responses to complaints). TPV and sales script preparation and opinions to ensure regulatory compliance. Marketing and "Do Not Call" List compliance and enforcement matters. Ongoing state and FCC compliance filings and reports.  Customized FCC compliance plans showing company-specific FCC filing obligations available at fixed fees.  Back to Top   Federal/State Policy Representation   The Firm actively represents clients before federal and state agencies, the Executive Branch, state public utilities commissions and national standards organizations regarding legal issues affecting a broad spectrum of domestic and international telecommunications. On the federal level, the Firm has represented clients before the FCC, the National Telecommunications and Information Administration of the Department of Commerce as well as the Departments of Justice, State, and Interior. In recent years, we have also been active on behalf of client interests before the White House, Department of Defense, Office of Homeland Security, FBI, and Committee on Foreign Investments in the United States. Our experience encompasses public policy proceedings; enforcement/compliance problems; ratemaking/pricing issues; numbering issues; contested payphone compensation issues; unsolicited fax advertising or “junk fax” disputes, to name a few.   On the state level, the Firm has significant experience in representing clients before state public utilities commissions. We have, at one time or another, been active before each state commission with respect to a wide range of matters, including contested hearings, enforcement investigations, transfer and asset acquisition applications, certification matters and general compliance issues. The Firm has prosecuted certification and transfer of control applications in all fifty states. Significantly, we also have unique experience in drafting the telecommunications regulations for the public utilities commission of a U.S. territory.   Back to Top    Wireless   We have significant experience in representing diverse clients offering mobile services, including Personal Communications Services (PCS), cellular, resellers or Mobile Virtual Network Operators (MVNOs), Specialized Mobile Radio (SMR), satellite and other wireless technologies. Our wireless experience encompasses FCC licensing and renewal, FCC auctions, frequency coordination and interference issues, local number portability, E911, CALEA, spectrum relocations (including the ongoing 800MHz relocation), eligible telecommunications carrier (ETC) status, enforcement and compliance matters, state regulation of wireless services, sales and acquisitions including FCC approval and related matters. The Firm recently represented a wireless service provider in the acquisition of a large number of PCS and SMR licenses, handling the regulatory due diligence process, contract negotiation and preparation and submission of the necessary FCC assignment applications. Our experience also includes having represented an SMR dispatch taxi cab service in a major metropolitan market as well as several hospitals with respect to their paging operations.   Back to Top    VoIP/Prepaid/Internet   The Firm represents growing numbers of VoIP, prepaid and Internet-based service providers offering a diverse array of communications services.  Our experience includes counseling and representing such entities in a wide range of contexts, including regulatory/compliance, enforcement proceedings, federal and state entry and licensing, commercial transactions and disputes as well as on other issues.  Our representation of VoIP or IP-telephony providers covers all FCC matters, including E911 and CALEA compliance as well as USF compliance requirements.  The Firm has represented a large number of prepaid calling card providers since the mid-1990s and is well-positioned to counsel and represent both established prepaid providers (and underlying wholesale providers) as well as start-up entities.  Finally, we have significant experience in representing innovative providers of Internet-based communications services in all communications-related legal areas.      Back to Top   Information Services   The Firm counsels a wide range of clients relative to unregulated enhanced or value-added services, including electronic mail, travel services, document management, automated processing, facsimile services, messaging, 900 or pay-per-call services, teleconferencing platforms as well as other innovative value-added offerings.  Many of our clients are providers of diverse information or enhanced service offerings. Increasingly, businesses offering such applications require assurance that their products fall outside the scope of telecommunications regulation and USF contribution requirements and call upon us to assist in making these determinations. In a number of instances, such entities have been identified, in many cases improperly, by regulators as being subject to regulatory requirements or contributory assessments. We assist such companies in defending against these actions. The Firm also has significant experience in advising enhanced prepaid telecommunications providers in structuring their prepaid platforms so as to steer clear of federal and state regulatory requirements, offering opinion letters to support our conclusions. In addition, we assist such companies in complying with federal and state regulatory requirements, where applicable.    Back to Top   Commercial Transactions     The Firm has substantial expertise in business transactional matters and offers a wide range of telecommunications contract drafting and negotiation services. The Firm has drafted and/or negotiated a variety of commercial agreements on behalf of domestic and foreign telecommunications providers. By way of example, the types of agreements we have either drafted or negotiated include the following: Reseller agreements with underlying service providers. A range of carrier/customer agreements. Distributor agreements for prepaid providers. Sales agent agreements for both carriers and sales agents. Stock and asset purchase agreements for long distance and wireless providers. International settlement agreements for service providers. Turnkey management agreements for long distance and wireless providers. Licensing agreements. Settlement and dispute resolution agreements. Nondisclosure and confidentiality agreements. Letters of intent; and much more. The Firm regularly represents communications companies in diverse commercial transactions, including asset and stock purchases as well as public offerings. We also have substantial experience in the due diligence process surrounding such transactions as well as in securing regulatory approvals for such transactions before federal regulators and virtually all of the state public utilities commissions.    Back to Top   Litigation   While negotiation and settlement can sometimes bring about the most cost-effective resolution to a contested case, sometimes aggressive litigation is the only alternative. We are well-prepared for either contingency. We provide representation before Federal courts, in administrative proceedings before federal agencies and before state public utilities commissions. The Firm's attorneys also have experience in arbitration and mediation proceedings. As appropriate, we serve as co-counsel in state court and administrative matters where our specialized expertise is required. Litigation experience includes representing a government entity in opposing injunctive relief before the U.S. Court of Appeals, representing both plaintiffs and defendants in Federal District Court, and representing long distance resellers in enforcement proceedings before the FCC. The Firm's principal attorney also regularly represented various clients, including a large computer equipment manufacturer, before the U.S. District Court in connection with the AT&T Consent Decree before it was terminated in 1996.    Back to Top   End User   We routinely represent large users of telecommunications services, including Fortune 500 companies and other organizations, with respect to a range of communications/technology issues, including contracting with major service providers, Universal Service Fund and other regulatory charges, the Federal Excise Tax and FET refund claims at the IRS, FCC licensing obligations, toll fraud, number portability and service provider opportunities. By way of example, our representation has encompassed review/analysis of carrier service agreements, negotiations with carriers, counseling with respect to maximizing value (including credits and rate stability issues), counseling with respect to termination/shortfall liability and business downturn issues, contract renegotiations, related Service Guide and tariff questions as well as handling contested disputes with service providers. Recent experience includes service agreements with T-Mobile, AT&T, MCI WorldCom, XO, Sprint, and several former Regional Bell Operating Companies. In addition to corporations, we have also represented hospitals, non-profit organizations and educational institutions with respect to their service provider agreements.    Back to Top   Legislative   The Firm represents clients with respect to legislative issues before the U.S. Congress regarding matters affecting the telecommunications industry. For example, the Firm lobbied actively and successfully on behalf of one of its clients with respect to the Telecommunications Act of 1996 and the Y2K Act. Our legislative practice includes preparing testimony, counseling clients, testifying at Congressional hearings, drafting proposed legislation, tracking and advising clients on developing legislation and meeting with Members of Congress and their staff to further a client's objectives.    Back to Top   International   Over the years, the Firm has assisted non-U.S. companies and governments in both entering and understanding the U.S. telecommunications market. These companies and governments represent interests in many regions of the world, including Latin America (i.e., South America, Central America and Mexico), Asia and the Pacific Rim, Russia, Europe and the Caribbean. In recent years, we have represented growing numbers of businesses in South America, Central America and Mexico in understanding the evolving legal and regulatory requirements of the U.S. telecommunications market, including the entry process, regulatory fees and assessments (including the Universal Service Fund), ongoing compliance requirements, and the unique obligations imposed on foreign-owned providers. The Firm also has expertise in representing organizations situated in, and competing in, the Pacific Rim region, particularly Guam, the Commonwealth of the Northern Mariana Islands and American Samoa. The Firm previously served as telecommunications counsel to two of the governments of these pacific territories and represents a number of wireline and wireless service providers as well as other entities in these regions. We also have additional expertise representing both U.S. and non-U.S. companies and governments with respect to foreign ownership issues, ITU Convention matters, international numbering, ISPC codes, submarine cables, callback services, rate integration and the FCC's international settlements policy.   Back to Top