Photo of Brooke Kahn

Brooke Kahn is an associate in the firm’s Washington, DC office and a member of the Communications and Media and Data Privacy and Cybersecurity Practice Groups.

Acting Chairwoman Jessica Rosenworcel has announced that at its next monthly public meeting on June 17, the Federal Communications Commission (“FCC”) will kick off a process to change its equipment authorization rules and competitive bidding procedures to address national security threats.

The draft Notice of Proposed Rulemaking (“NPRM”), released Thursday, proposes changes to the FCC’s rules on equipment authorization that could restrict and revoke the authorization of devices determined to pose a threat to national security—effectively banning them from the U.S. marketplace.  The NPRM also proposes updates that would effectively require parties bidding for spectrum licenses or FCC broadband funding to certify that they will not rely on financial support from entities designated by the FCC as a national security threat.


Continue Reading FCC Announces New Efforts to Block “Insecure Devices” from the U.S. Market

Earlier this month, the Federal Communications Commission (“FCC”) issued an Enforcement Advisory reminding manufacturers, importers, and retailers of video TV set-top boxes that stream Internet-based content to comply with FCC device authorization rules.  As the FCC noted in its Advisory, violations of these rules can lead to monetary penalties totaling more than $19,000 per day of violation or $147,000 for an ongoing violation.  The Advisory noted that to avoid these penalties, entities that manufacture, import, market or operate these set-top boxes should ensure that they comply with FCC device authorization rules.

Continue Reading FCC Warns Marketers of Video Streaming Devices to Comply with Device Authorization Rules

Innovative leaders worldwide are investing in technologies to transform their cities into smart cities—environments in which data collection and analysis is utilized to manage assets and resources efficiently.  Smart city technologies can improve safety, manage traffic and transportation systems, and save energy, as we discussed in a previous post.  One important aspect of a successful smart city will be ensuring infrastructure is in place to support new technologies.  Federal investment in infrastructure may accordingly benefit both smart cities and smart transportation, as explained in another post on connected and autonomous vehicles (“CAVs”).

Given the growing presence of CAVs in the U.S., and the legislative efforts surrounding them, CAVs are likely to play an important role in the future of smart cities.  This post explores how cities are already using smart transportation technologies and how CAV technologies fit into this landscape.  It also addresses the legal issues and practical challenges involved in developing smart transportation systems.  As CAVs and smart cities continue to develop, each technology can leverage the other’s advances and encourage the other’s deployment.


Continue Reading IoT Update: How Smart Cities and Connected Cars May Benefit from Each Other

Since the Federal Communications Commission (“FCC”) repealed the 2015 net neutrality rules last year, federal and state lawmakers have debated how to address the issue of net neutrality going forward.  We previously have discussed some of the state net neutrality laws that were enacted, including California’s law, which currently is on hold pending the resolution of Mozilla Corp v. FCC, the lawsuit challenging the FCC’s order that repealed net neutrality rules.  Oral argument for this case was held in the U.S. Court of Appeals for the D.C. Circuit on February 1, 2019.

Continue Reading Net Neutrality Update: House Hearing and Proposed Legislation