Advisories

FTC’s 2025 Amendments to the Children’s Online Privacy Protection Rule (COPPA): What Operators Must Do Now

On April 22, 2025, the Federal Trade Commission (“FTC” or “Commission”) published final amendments to the Children’s Online Privacy Protection Rule (“COPPA Rule” or “Rule”), marking the first comprehensive update since 2013. The 2025 COPPA Rule amendments represent a significant expansion of children’s privacy protections with substantial new compliance obligations. While enhancing protections for children, […]

FTC Sues Uber for Deceptive Billing and Cancellation Practices

The Federal Trade Commission (“FTC”) filed a complaint on April 21, 2025, in the U.S. District Court for the Northern District of California against Uber Technologies, Inc. and Uber USA, LLC (collectively, “Uber”). The agency alleges violations of Section 5(a) of the FTC Act and Section 4 of the Restore Online Shoppers’ Confidence Act (“ROSCA”) stemming from Uber’s subscription program, Uber One. According to the FTC’s […]

Fifth Circuit Invalidates FCC Forfeiture Order Against AT&T Based on SEC v. Jarkesy Precedent—Implications for FCC Enforcement and Telnyx’s $4.5M NAL Dispute

In a landmark decision issued on April 17, 2025, the U.S. Court of Appeals for the Fifth Circuit vacated a $57 million forfeiture order imposed by the Federal Communications Commission (FCC) against AT&T. The court held that the FCC’s in-house adjudication process violated AT&T’s constitutional rights, specifically referencing the Supreme Court’s 2024 decision in SEC v. Jarkesy. The SEC […]

DOJ Final Rule on Transfers of Bulk U.S. Sensitive Personal Data to Countries and Persons of Concern Is Now Effective: Major Implications for Companies that Provide Third Parties Access to Personal Data

The U.S. Department of Justice’s (DOJ) final rule implementing Executive Order 14117 (Final Rule) went into effect on April 8, 2025. The Final Rule establishes sweeping prohibitions and restrictions on access to sensitive U.S. personal data and government data by countries of concern and covered persons as defined in the rule.  On April 11, DOJ […]

FTC Seeks Public Comment on Anti-Competitive Federal Regulations

On April 14, 2025, the Federal Trade Commission (FTC) issued a public Request for Information (RFI) seeking comment on how existing federal regulations may unnecessarily restrict competition. This initiative is part of a broader mandate under Executive Order 14267, which directs agencies to identify and eliminate anti-competitive regulatory barriers that stifle innovation, protect dominant incumbents, […]

Red, White & Be Careful: FTC Compliance for “Made in the USA” Claims

Several prominent companies, including Apple, Toyota, Corning, and GE, recently announced plans to invest in or expand manufacturing operations in the United States (“US”). As manufacturing relocations increase and costs continue to rise, consumers may look to domestically produced goods to stretch their budgets. Companies either moving manufacturing to the US or already engaging in […]

FCC “Delete Delete Delete” Proceeding – Comments Filed by Cloud Communications Alliance

On April 10, 2025, the Cloud Communications Alliance (CCA) filed comments in response to the FCC’s recently initiated “Delete Delete Delete” proceeding, championed by Chairman Carr. The Delete Delete Delete proceeding aligns with President Trump’s broader deregulatory agenda, as detailed in Executive Orders such as Executive Order 14192 titled “Unleashing Prosperity Through Deregulation” and Executive Order 14219 titled “Ensuring Lawful Governance And Implementing The President’s […]

FCC Delays Effective Date of New Rule Requiring Callers to Cease All Forms of Robocalls and Robotexts in Response to a Revocation of Authority for One Type of Message

The Federal Communications Commission (“FCC” or “Commission”) Monday released an Order, delaying by one year the effective date of a new regulation that states “[i]f a called party uses any [reasonable] method to revoke consent, that consent is considered definitively revoked and the caller may not send additional robocalls and robotexts.” In other words, the […]

FCC Seeks Comment on Accessibility in Next Generation 911 (NG911) Rulemaking

On March 27, 2025, the Federal Communications Commission (FCC) adopted a Further Notice of Proposed Rulemaking (FNPRM) aimed at enhancing the resiliency, reliability, interoperability, and accessibility of Next Generation 911 (NG911) networks. As NG911 evolves to support a full range of 911 communications, including voice, text, data, and video, the FCC is particularly focused on […]

Changes to TCPA Rules on Revocation of Consent Scheduled to Take Effect on April 11, 2025

In 2024, the Federal Communications Commission (FCC) adopted new rules aimed at simplifying the process for consumers to revoke consent for robocalls and robotexts. These updates were outlined in its Report and Order and Further Notice of Proposed Rulemaking titled “Strengthening the Ability of Consumers To Stop Robocalls.”  As mentioned in our prior client advisory, with these […]

Beneficial Ownership Information Reporting No Longer Required for U.S. Companies; FinCEN Announces Filing Deadlines for Foreign Companies Doing Business in U.S.

On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule (IFR) that significantly changes the scope of beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA). As we previously reported, FinCEN has suspended enforcement of the CTA. Key Changes Exemption for U.S. Entities: The IFR removes the […]

FCC Seeks Comments on Transitioning Entire 900 MHz Band for Broadband Use, Based on Voluntary Negotiations

The Federal Communications Commission’s (“FCC” or Commission”) Notice of Proposed Rulemaking and Order (“NPRM”), seeking comments on its proposals to increase broadband service utilizing the 896–901/935–940 MHz spectrum band (“900 MHz Band”), has recently been published in the Federal Register, which sets the comment deadlines. Comments are due by May 16, 2025, and reply comments […]

FCC Announces Proposed 36.6% USF Contribution Factor for Q2 2025

The FCC’s Office of the Managing Director has announced the proposed Universal Service Fund (USF) contribution factor for the second quarter of 2025 will be 36.6%, a 0.3% increase from last quarter’s 36.3% in the Public Notice. This continued rise sets another record high, further increasing the financial burden on telecommunications providers. Covered in our […]

Correction: Upcoming RCCCI CVAA Filing Deadline – April 1

In our previous advisory on the upcoming RCCCI CVAA filing deadline, we included references to requirements for certain service providers, such as Incarcerated People’s Communications Services (IPCS), to file their annual recordkeeping compliance certifications and contact information with the FCC by April 1, 2025. It has come to our attention that the CVAA certification portal […]

California Privacy Protection Agency Fines Honda for Demanding Verification Information from Consumers Opting Out of Data Sale or Sharing

In an increasingly digital world, consumer privacy has become a paramount concern, leading to the establishment of laws like the California Consumer Privacy Act (CCPA). Recently, the California Privacy Protection Agency (CPPA) resolved an enforcement action against American Honda Motor Co., Inc. (Honda) highlighting the importance of honoring consumer requests to exercise privacy rights.  Case […]