K.C. Halm

K.C. Halm

Davis Wright Tremaine LLP

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Latest Publications


FCC Seeks Input on Open Internet Transparency Exemption

Smaller broadband providers now have an opportunity to convince the FCC to maintain the small provider exemption from the new “enhanced” transparency (disclosure) requirements of the 2015 Open Internet Order. As we explained...more

7/23/2015 - AT&T Mobility Exemptions FCC Internet Mobile Broadband Services OMB Open Internet Rules Transparency

FCC Proposes Record $100 Million Penalty for Alleged Violations of Open Internet Transparency Rule

If you work for a broadband service provider and haven’t recently reviewed your FCC-mandated network management “transparency” disclosures posted on your website, we suggest you make that the next thing you do after reading...more

7/23/2015 - AT&T Mobility Breach of Contract Broadband Compliance Data Plan Disclosure Requirements FCC Fines Misrepresentation Mobile Devices Open Internet Rules Transparency Unjust Enrichment

Are Your Disclosures Sufficient Under the “Enhanced” Transparency Rule?

Although not yet in effect, broadband providers should begin to consider how best to implement the FCC’s “enhanced” transparency (disclosure) requirements. As explained in our recent advisory, the Order retains the FCC’s 2010...more

7/23/2015 - Broadband Compliance Disclosure Requirements FCC OMB Safe Harbors Terms of Service Transparency Directive

FCC Proposes Unprecedented Fine of $100 Million for Alleged Violations of Open Internet Transparency Rule

The FCC issued a Notice of Apparent Liability (“NAL”) to AT&T for alleged violations of the 2010 Open Internet “transparency rule.” The FCC contends that AT&T “willfully and repeatedly” violated the rule by: (1) using the...more

6/24/2015 - AT&T Broadband Data Plan Disclosure Requirements FCC Misleading Statements Mobile Broadband Services Open Internet Rules Refunds Transparency

Open Internet Order Published and to Become Effective on June 12, 2015—Numerous New Appeals Expected

The FCC’s Open Internet Order (the “Order”) was published in the Federal Register today, Monday, April 13, and, unless the Order is stayed, will become effective after sixty days, on June 12, 2015. Publication in the Federal...more

4/14/2015 - Covered Entities Data Collection FCC Judicial Review Open Internet Rules

“Enhanced” Transparency Requirements Expand Current Disclosure Obligations (But Temporarily Exempts Smaller Providers)

The Order does not formally modify the text of the existing “transparency” rule, which was upheld by the D.C. Circuit in Verizon v. FCC in 2014. However, the Order does prescribe numerous “enhancements” to the rule, which...more

3/18/2015 - Broadband Disclosure Requirements Transparency

FCC Applies Section 222 to BIAS Providers, but Delays Specialized Rules

The Order does not forbear from applying Section 222 of the Act to broadband Internet access service (BIAS) providers. It did, however, forbear from applying its existing rules implementing Section 222, in recognition that...more

3/18/2015 - Broadband Data Collection Enforcement FCC Personally Identifiable Information

FTC Staff Report on Internet of Things: Recommends Self-Regulation “Best Practices,” But Leaves Key Issues Unresolved

The Federal Trade Commission released its much anticipated staff report on January 27 regarding consumer privacy and data security concerns arising from the emerging market for connected devices known as the Internet of...more

2/3/2015 - Best Practices Cybersecurity Data Protection FTC Information Reports Internet Internet of Things Popular

New FTC Report on IoT Maintains Need for Baseline Privacy Legislation and Begins to Recognize Limitations of FIPPS in a Connected...

The Federal Trade Commission released its long awaited staff report on privacy and security issues presented by the emerging market for connected devices, also known as, the Internet of Things (“IoT”) (the “Report”) this...more

1/28/2015 - FTC Information Reports Internet of Things Internet Privacy Proposed Standards

FCC Sets Dec. 15 Deadline for Special Access Data Collection Submissions

December 15 is now set as the deadline by which nearly all cable operators, telecommunications carriers, and many others must respond to an extensive FCC special access data collection, per an Order on Reconsideration...more

9/18/2014 - Data Collection Deadlines FCC Telecommunications

FCC Establishes Application Procedures for Rural Broadband Experiments – Application Deadline Set for Oct. 14

On August 19, the FCC’s Wireline Competition Bureau released a public notice establishing the process for applying for support under the Rural Broadband Experiments program. Applications under this program must be submitted...more

8/26/2014 - Applications Auction Broadband FCC Rural Broadband Experiments

FCC to Proceed with Revised Special Access Data Collection Effort Following OMB Approval

On Aug.15, the Office of Management and Budget (OMB) approved the FCC’s proposed special access services data collection plan, subject to several modifications that limit the initial scope of the plan. The FCC’s special...more

8/21/2014 - Data Collection FCC OMB

FCC Initiates Rural Broadband Experiments Program: $100 Million to be Disbursed to Winning Bidders

On July 14, 2014, the Federal Communications Commission (“FCC”) released its latest Connect America Fund Order, which sets forth the parameters of its planned “rural broadband experiments” program. As detailed below, the...more

7/18/2014 - Broadband FCC Internet Internet Service Providers Rural Development

FCC Allocates $100 Million for Rural Broadband Experiments –Agency Will Reward Providers That Can Deliver Broadband at Speeds up...

On Friday, July 11, 2014 the FCC adopted an order implementing its planned “Rural Broadband Experiments”—a test-case program for disbursing subsidies to competitive providers that can deploy broadband to unserved areas. Our...more

7/18/2014 - Broadband FCC National Broadband Plan Rural Development Subsidies

Broadband Providers Must Guard Against Subsidized Overbuilds as FCC Readies $9 Billion to Deploy Broadband to “Unserved” Areas

Phase II of the FCC’s Connect America Fund (“CAF”) program will disburse up to $9 billion in support (i.e., subsidies) over the next five years to price cap incumbent local exchange carriers (“ILECs”). This support will be...more

7/8/2014 - Broadband Connect America Fund FCC Internet Internet Service Providers

Competitive Providers One Step Closer to Support for Rural Broadband Deployment Following Latest FCC CAF Phase II Order

On Wednesday, June 11, 2014, the Federal Communications Commission (FCC) released its long-awaited order establishing a framework for competitors to obtain broadband subsidies (support) through Phase II of the Connect...more

6/13/2014 - Broadband Cable Television Providers Connect America Fund FCC ISPs

FCC Proposes to Make 150 MHz of Spectrum Available for Shared Broadband Through Use of Dynamic Spectrum Access and Sharing Systems

Yesterday, the Federal Communications Commission (FCC) took steps to make 150 megahertz of spectrum available for shared broadband use by unanimously approving a Further Notice of Proposed Rulemaking (FNPRM) setting forth...more

4/24/2014 - Broadband FCC NPRM Wireless Industry

FCC Authorizes Additional 100 MHz of Unlicensed Spectrum in 5 GHz Band (Part 2: Key Takeaways from the Report and Order)

In our last post on this topic, we reported on the FCC’s adoption of an order authorizing the use of an additional 100 MHz of unlicensed spectrum for Wi-Fi and related network equipment. Now that the order has been released,...more

4/17/2014 - FCC Telecommunications Wireless Technology

FCC Authorizes Additional 100 MHz of Unlicensed Spectrum in 5GHz Band

Gigabit Wi-Fi services are one step closer to reality following the Federal Communications Commission’s (FCC) decision to unanimously adopt an order today, March 31, 2014, authorizing use of an additional 100 MHz of...more

4/1/2014 - FCC Networks Wifi Wireless Industry Wireless Technology

FCC Makes Estimated $50 to $100 Million Available to Competitors Deploying Broadband in Rural Areas for the First Time

Competitive providers deploying broadband networks in rural areas will now be eligible to obtain direct subsidy support from the Federal Communications Commission (FCC) through an experimental program under the Connect...more

2/27/2014 - Broadband CAF FCC ISPs Rural Development Telecommunications

FCC I/S/O Providers to Experiment with Rural Broadband Deployments Under Connect America Fund Phase II

As we recently reported, the Federal Communications Commission’s (FCC) “IP Transition Order” includes an experiment designed to test the feasibility of directing Connect America Fund (CAF) subsidies to competitive providers...more

2/12/2014 - Broadband Connect America Fund FCC ISPs

The Anonymization/De-identification Debate Moves to the FCC

As explained in our recent PrivSec blog post, on Dec. 11, 2013, a coalition of privacy advocates led by Public Knowledge filed a Petition for Declaratory Ruling with the FCC that, if granted, would significantly expand the...more

1/7/2014 - Data Collection FCC Internet Personally Identifiable Information Privacy Laws Telecommunications

Responses to FCC Survey of Fixed Voice and Broadband Rates in Urban Areas (aka Urban Rate Survey) Due Jan. 17, 2014

The FCC recently announced that respondents to the Commission’s “urban rate survey” must complete survey responses no later than Jan. 17, 2014. The urban rate survey is an FCC initiative to collect information of fixed voice...more

12/19/2013 - Broadband FCC Surveys

Comments Due January 10, 2014 on Issues Raised in FTC's Internet of Things Workshop

Following its highly publicized workshop exploring consumer privacy and security issues arising from the emerging market of the Internet of Things, the Federal Trade Commission (FTC) is now calling for filed comments on...more

12/17/2013 - Data Collection FTC Internet Internet of Things Right to Privacy

Latest FTC Enforcement Action Reflects Agency's Intent to Focus on Emerging Market Involving the "Internet of Things"

In its first enforcement action against a company operating in the emerging market known as the “Internet of Things”, the FTC has secured a settlement agreement with a company that markets Internet-connected video cameras...more

9/9/2013 - Compliance Cybersecurity Data Protection Enforcement Actions FTC Internet Surveillance

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