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Thomas Parisi is an associate in the firm’s Washington, DC office. He joined the firm after serving as an attorney at the Federal Communications Commission.

Mr. Parisi focuses his practice on a wide range of issues across the communications and technology sectors. In particular, he focuses on a number of telecommunications issues, including broadband policy, universal service, competition, and communications-related transactions. Mr. Parisi also works on data protection and privacy issues, with an emphasis on compliance with federal and international privacy laws and regulations. He helps clients across these industries understand the implications of new regulations and proposals to prepare them for compliance with the policies and engagement on shaping policy outcomes.

A little over a month ago, the deadline for appealing the D.C. Circuit’s decision in Mozilla v. FCC expired.  The Mozilla decision upheld the FCC’s 2017 Restoring Internet Freedom Order (“Order”), which rolled back Obama-era net neutrality regulations to largely deregulate broadband internet service provider (“ISP”) practices.  No party sought Supreme Court review

With all the current excitement around emerging high-tech autonomous vehicles and internet of things (IoT) devices, it may surprise some observers that around 20 years ago the Federal Communications Commission (FCC), at Congress’s direction, was already taking some important steps with respect to these technologies.  Most notably, the FCC set aside the 5.9 GHz band, which is a swath of highly-valued mid-band spectrum, for vehicle related communications and transportation safety features.  At that time, the FCC pursued Dedicated Short Range Communications (DSRC) as the standard to develop critical safety services, but over time, similar technologies outside of the 5.9 GHz band have developed.  More recently, a number of manufacturers and developers have been focused on a new technology called Cellular Vehicle to Everything (C-V2X), which proponents argue should be the standard going forward.

The FCC has decided to weigh in on the issues in the 5.9 GHz band in a draft notice of proposed rulemaking (NPRM) to be voted on at its December 12 Commission Open Meeting.  The 5.9 GHz band has been a political issue subject to disagreements among the FCC, Department of Transportation, and members of Congress on both sides of the aisle, regarding the best path forward, which technologies should be pursued, and whether there is enough spectrum that can safely be shared among different use cases. 
Continue Reading IoT Update: FCC Proposes New Spectrum Plan for Vehicle Safety and Unlicensed Uses

In a long-awaited decision, today the U.S. Court of Appeals for the D.C. Circuit upheld a January 2018 decision by the FCC to repeal most net neutrality rules and classify broadband as an unregulated “information service,” despite requiring the FCC to conduct further proceedings to justify certain aspects of its decision.  At the same time, the Court found that the FCC exceeded its authority in attempting to preempt any state net neutrality or similar laws regulating broadband.
Continue Reading Federal Appellate Court Largely Upholds FCC’s Order Repealing Most Net Neutrality Rules and De-Regulating Broadband; Holds that FCC Does Not Have Authority to Preempt All State Net Neutrality Laws

From the Federal Communications Commission (“FCC”) to Congress to the White House, the federal government has continued to push the importance of investment and innovation in fifth-generation (“5G”) wireless technology. This push bodes well for the many industries that rely on the Internet of Things (“IoT”), such as transportation, healthcare, and manufacturing—to name a few. As we have previously discussed, 5G deployment is critical for IoT because the IoT ecosystem will rely heavily on the increased speeds and capacity, as well as the reduced latency, that 5G technology will enable. Below we discuss the most recent pushes for 5G developments from federal leadership before surveying key industries in the IoT ecosystem that we expect to benefit from these efforts.
Continue Reading IoT Update: Flurry of Federal 5G Activity Indicates Important Growth Opportunities for the IoT Ecosystem

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

On November 30, 2018, the Federal Communications Commission (“FCC”) hosted a forum to discuss artificial intelligence (“AI”) and machine learning. Chairman Ajit Pai moderated the forum’s two main panels “What Is AI and Where Is It Taking Us?” and “Applications of AI and Machine Learning in the Here and Now,” which invited academics, industry professionals, and government affairs specialists to weigh in on the evolving AI ecosystem.

Chairman Pai made clear in his opening remarks that the purpose of the forum was not to initiate AI regulation at the FCC. He stated: “It’s important to note that this event is about discussion and demonstration. It is not about the FCC dipping its toes in the regulatory waters. These are emerging technologies. And when dealing with emerging technologies, I believe that one of the foundational principles for government should be regulatory humility.” This sentiment of sharing information about new AI issues and best practices was lauded by many of the panelists as the correct approach in the sphere. They explained that to create “AI regulation” would be a particularly challenging endeavor because AI has so many different applications across all different sectors.

Although the Chairman is not looking to AI regulation at the FCC, he does see an important role for the agency to play: facilitating the deployment of 5G. The promise of 5G to advances in AI became a consistent theme among the Chairman, the panelists, and Commissioners Carr and Rosenworcel. The Commissioners delivered remarks at the forum as well.
Continue Reading AI Update: FCC Hosts Inaugural Forum on Artificial Intelligence

5G deployment and availability will greatly expand and enhance the Internet of Things (IoT). As we explored in a prior post, apart from spectrum availability, one of the other primary keys to promoting 5G development is increased investment in both wireless and wireline infrastructure. Without the necessary infrastructure (e.g. small cells, fiber backhaul) to support advanced 5G offerings, nascent IoT technologies will be inhibited by ever-increasing capacity demands that put strains on the existing infrastructure.

On September 26, 2018, the Federal Communications Commission (FCC) voted to approve a Declaratory Ruling and Third Report and Order (Order) designed to encourage and facilitate the investment necessary to deploy infrastructure to meet the demands of 5G networks. As the FCC explained in the Order, 5G is so important because it can “enable increased competition for a range of services—including broadband—support new healthcare and Internet of Things applications, speed the transition to life-saving connected car technologies, and create jobs.”
Continue Reading IoT Update: FCC Efforts to Encourage 5G Infrastructure Investment

As we explained in a prior post, 5G deployment will be a critical component to the ever-evolving Internet of Things (IoT). On April 17, the Federal Communications Commission (FCC) adopted a Public Notice seeking comment on the competitive bidding procedures for auctions involving spectrum in the 28GHz and 24 GHz bands. The auction of 28 GHz spectrum will begin on November 14, with the 24 GHz auction following after that. But what does this mean, and why is it important?

For those new to the world of FCC Auctions, a Comment Public Notice, such as the one just released, seeks input on the application process for the auctions and the procedures to be used while bidding. It is similar in form to a Notice of Proposed Rulemaking, in which the FCC seeks comments on a proposal and asks a variety of questions. After the comment and reply comment deadlines pass (May 9 and May 23, respectively), the FCC will take into consideration the input on the record. Next, the FCC will release a Procedures Public Notice, akin to an Order, that will lay out the rules that will be in force for the auction. The FCC will also announce the application windows to participate in the auction, and interested parties will apply to participate. This will all take place before the start of bidding in November.
Continue Reading Covington Internet of Things Update: The FCC Gets Ready for 5G Spectrum Auctions

Updated (5/3/2018)

On April 17, the Federal Communications Commission (“FCC”) broke new ground in the agency’s role in national security policy by voting unanimously to approve a Notice of Proposed Rulemaking captioned “Protecting Against National Security Threats to the Communications Supply Chain Through FCC Programs” (the “NPRM”).  The deadline for filing comments is June 1, 2018, and reply comments are due July 2, 2018.

As the title indicates, the NPRM seeks comment on a framework to reduce supply chain risks for telecommunications equipment and services deployed throughout the country. The item acknowledges a specific role for the FCC in this arena: to ban use of Universal Service Fund (“USF”) subsidies in ways that undermine or pose a threat to national security. In short, the FCC proposes to use the power of the purse—in the case of USF, about $9 billion in subsidies per year—to dissuade companies from using equipment sourced from companies or countries that pose a national security concern.

Although the approach is narrow in scope, in practice the NPRM could produce a final rule that would significantly affect the selections of equipment and services by some USF recipients, particularly rural and smaller providers who reportedly are more likely to have purchased equipment from targeted suppliers. Additionally, as explained below, this proposed rule could affect USF recipients that do not use prohibited equipment and service providers, depending on whether some of their subcontractors use them.
Continue Reading Covington Internet of Things Update: FCC Looks to Bolster the Communications Supply Chain

Thermostats you control remotely with your phone. Watches that track runs and provide turn-by-turn navigation. Cars that drive themselves. The Internet of Things (IoT) is a remarkable ecosystem providing innovative and sometimes unexpected functions. But as the number and sophistication of connected devices increases, so too does the need for the infrastructure to handle increased network demands—making the rollout and success of 5G networks critical to the future of IoT.

Regulators at the Federal Communications Commission (FCC) are keenly aware of the importance of 5G, and with that in mind are taking steps to facilitate necessary upgrades to both wireless and wireline broadband technologies and infrastructure. We highlight some of these initiatives below.
Continue Reading Covington Internet of Things Update: 5G at the FCC, and What That Means for IoT