Last week, Chairwoman Jessica Rosenworcel of the Federal Communications Commission (FCC) announced that she expects to circulate a proposal shortly that will authorize the FCC and/or certain national security agencies to periodically evaluate the foreign ownership of FCC licensees in light of national security considerations. She made this announcement in a speech that focused on

Yaron Dori
Yaron Dori has over 20 years of experience in telecommunications, privacy, and consumer protection law, advising telecom, technology, life sciences, media and other types of companies on their most pressing business challenges. He is a former chair of the Communications and Media practice group and currently serves as a member of the firm’s eight-person Management Committee.
Yaron’s practice focuses on strategic planning, policy development, transactions, investigations and enforcement, and regulatory compliance.
He represents clients before federal regulatory agencies—including the Federal Communications Commission (FCC) and the Federal Trade Commission (FTC)—and the U.S. Congress in connection with a range of policy issues under the Communications Act, the Federal Trade Commission Act, and similar statutes. He also represents clients on state regulatory and enforcement matters, including those that pertain to telecommunications and data privacy regulation. His unique experience in telecommunications, privacy, and consumer protection enables him to advise clients on key business issues in which these areas intersect.
With respect to telecommunications matters, Yaron advises clients on a broad range of business, policy and consumer-facing issues, including:
- Broadband deployment and regulation;
- IP-enabled applications, services and content;
- Equipment and device authorization procedures;
- The Communications Assistance for Law Enforcement Act (CALEA);
- Customer Proprietary Network Information (CPNI) requirements;
- The Cable Privacy Act
- Net Neutrality; and
- Local competition, universal service, and intercarrier compensation.
Yaron also has extensive experience in structuring transactions and securing regulatory approvals at both the federal and state levels for mergers, asset acquisitions and similar transactions involving large and small FCC and state licensees.
With respect to privacy and consumer protection matters, Yaron advises clients on a range of business, strategic, policy and compliance issues, including those that pertain to:
- The California Consumer Privacy Act (CCPA);
- The Electronic Communications Privacy Act (ECPA);
- Location-based services that use WiFi, beacons or similar technologies;
- Online Behavioral Advertising;
- Online advertising practices, including native advertising and endorsements and testimonials; and
- The application of federal and state telemarketing, commercial fax, and other consumer protection laws, such as the Telephone Consumer Protection Act (TCPA), to voice, text, and video transmissions.
Yaron also has experience advising companies on FCC (Enforcement Bureau), FTC and state attorney general investigations into various consumer protection and communications matters, including those pertaining to social media influencers, digital disclosures, product discontinuance, and advertising claims.
FCC Commissioner Simington Proposes Mandatory Security Updates for Devices
Last week, in remarks at an industry conference, Republican FCC Commissioner Nathan Simington proposed that the FCC consider requiring electronic device manufacturers to “take reasonable steps” to protect device security, including requiring them to issue software or firmware updates to patch security flaws and ensure that devices are designed to be easily patched.
His remarks…
FCC Bans “Untrustworthy Communications Equipment” from the U.S. Market; Measure Could Have Broader Implications for All Device Manufacturers
On November 25, 2022, the FCC effectively banned certain Chinese telecom and video surveillance devices from the U.S. market – demonstrating the power of its authority over virtually all electronics equipment, which until last week’s decision had been exercised only to address technical, scientific and engineering concerns. With Congressional backing, the FCC now has established…
FTC Flexes ROSCA Muscle with $100 Million “Dark Patterns” Settlement with Vonage
On November 3, the FTC announced that it entered into a significant $100 million settlement with Vonage to resolve allegations relating to the internet phone service provider’s sales and autorenewal practices. The FTC alleged that Vonage violated both the FTC Act and the Restore Online Shoppers’ Confidence Act (ROSCA) by failing to provide a simple cancellation mechanism, failing to disclose material transaction terms prior to obtaining consumers’ billing information, and charging consumers without consent.…
Continue Reading FTC Flexes ROSCA Muscle with $100 Million “Dark Patterns” Settlement with Vonage
Federal Government Issues Multi-Billion Dollar Notices of Funding Opportunity for Broadband Programs
Last Friday, the National Telecommunications and Information Administration (“NTIA”) took a major step in furtherance of the Biden Administration’s goal of connecting all Americans to broadband by releasing its widely anticipated Notice of Funding Opportunity (“NOFO”) for the landmark $42.5 billion Broadband Equity, Access, and Deployment (“BEAD”) Program, along with NOFOs for two smaller programs. …
NTIA Seeks Comment on Competition in the Mobile App Marketplace
On Friday, April 22, 2022, the National Telecommunications and Information Administration (NTIA), which is part of the Department of Commerce, issued a request for comment (RFC) on the state of competition in the mobile app marketplace. According to the RFC, the record developed will be used to inform the Biden Administration’s competition agenda, including a report on competition in the mobile app ecosystem. Comments are due on May 23, 2022.
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FCC Considering Changes to Emergency Alert Service Rules; Collecting Information About Potential Application to Streaming Services
Last week, the Federal Communications Commission (FCC) released a Notice of Proposed Rulemaking (NPRM) and Notice of Inquiry (NOI) regarding its Emergency Alert Service (“EAS”) rules. These rules govern how emergency alerts are transmitted by federal, state, local, Tribal, and territorial officials to the public over mobile phones, radios, and televisions.
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FCC Imposes New Requirements on Nonmarketing Prerecorded Calls to Residential Lines
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Continue Reading FCC Imposes New Requirements on Nonmarketing Prerecorded Calls to Residential Lines
FCC Seeks Comment on Proposal to Change Device Marketing Rules
The Federal Communications Commission (“FCC”) is seeking comment on a Notice of Proposed Rulemaking (“NPRM”) that would modify certain aspects of the FCC’s device authorization rules. Specifically, the FCC is seeking comment on a proposed revision to its device authorization rules to allow the importation of limited quantities of radiofrequency (“RF”) devices prior to authorization for pre-sale activities, including imaging, packaging, and delivery to retail locations. The FCC also is proposing rule revisions that would allow conditional sales, but not delivery, of RF devices to consumers prior to authorization.
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FCC Plans to Advance Proposal to Change Device Marketing Rules
In what is expected to be one of the last meetings under the leadership of current Federal Communications Commission (“FCC”) Chairman Ajit Pai, the agency will consider adopting a Notice of Proposed Rulemaking (“NPRM”) that proposes to modify certain aspects of the FCC’s device authorization rules. Specifically, the NPRM will propose to allow the importation and conditional marketing and sales of radiofrequency (“RF”) devices that have not yet been approved under the FCC’s rules. If the rule is ultimately changed, that means companies marketing RF devices for the first time will have the same flexibility enjoyed by some car companies and many other manufacturers to offer a product to the public before it actually can be shipped for use.
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Continue Reading FCC Plans to Advance Proposal to Change Device Marketing Rules