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Yasamin Kubba

In the lead up to the Federal Communications Commission’s Rural Digital Opportunity Fund (“RDOF”) reverse-auction on October 29, 2020, the Commission released its draft Auction Procedures Public Notice (“Auction Procedures”) on May 19, 2020. The procedures for this auction, Auction 904, are expected to be approved by the Commission during its June 9 public meeting. …

Federal Communications Commission Releases Rural Digital Opportunity Fund Auction Procedures Public Notice, Spells Out Specifics of Requirements for Short-Form Versus Long-Form Read More »

Last Friday, the Federal Communications Commission (“FCC”) took the next step in cracking down on illicit robocalls by releasing an order (“Order”) adopting rules implementing Section 3 of the Pallone-Thune Telephone Robocall Abuse Criminal Enforcement and Deterrence Act, better known as the TRACED Act. The FCC did so without providing for public notice and comment, …

FCC Adopts TRACED Act Rules Eliminating Illegal Robocall Warnings, Increasing Penalties for Intentional Violations, and Extending Time to Bring Enforcement Actions Read More »

On April 1, 2020, the FCC released a Notice of Proposed Rulemaking (“NPRM”) proposing to deregulate and detariff remaining interstate end-user, access charges (together “End User Charges”)1 billed by incumbent local exchange carriers (“ILECs”), as well as prohibit competitive local exchange carriers (“CLECs”) from optionally tariffing similar charges. The new rules would also require all …

FCC Proposes Deregulating and Detariffing End User Charges and Simplifying Consumer Phone Bills — Comments Due 45 Days After Publication in the Federal Register Read More »

Along with its Report & Order requiring voice service providers to implement the STIR/SHAKEN caller ID authentication framework in the Internet Protocol (“IP”) portions of their networks by June 30, 2021, the FCC has recently released a Further Notice of Proposed Rulemaking (“FNPRM”) seeking public comments on various unresolved STIR/SHAKEN implementation issues. Initial comments are …

FCC Seeks Public Comments on Unresolved STIR/SHAKEN Implementation Issues — Comments Due May 15, 2020 Read More »

Intercarrier compensation is a topic most providers of over-the-top (“OTT”) VoIP services would find esoteric and archaic.  And, in the long-term, absent a major change in FCC policy, intercarrier compensation will likely disappear, except for toll-free calls that are paid by the toll-free subscriber.  Essentially, terminating Local and Tandem Switching are already gone except in …

Why Are Some OTT VoIP Providers Leaving Money on the Table? Read More »

As expected, the FCC released an OTT VoIP Access Order that rejected the ability of Over-the-Top (“OTT”) VoIP providers and their CLEC partners to bill originating end office switching charges. In 2011, the FCC’s Transformation Order, as part of its initial steps to phase-out access charges on interexchange calls adopted what is now the “VoIP …

FCC Holds Originating End Office Does Not Apply to OTT VoIP Calls Read More »

Earlier this year, the Connecticut Public Utilities Regulatory Authority (“PURA”) released an order relating to E-911 regulatory fees which, among other things, adopted new quarterly reporting requirements for certain providers offering communications services in Connecticut. The new reporting requirements apply to local telephone companies, Commercial Mobile Radio Services (“CMRS”), customer-owned coin operated telephone services (“COCOT”), …

Connecticut Public Utilities Regulatory Authority Adopts Quarterly E-911 Reporting Requirements for VoIP, CMRS, and Local Service Providers Read More »