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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 Chairman Pai announced today that the FCC will move forward with a rulemaking to clarify the meaning of Section 230 of the Communications Decency Act (CDA).  To date, Section 230 generally has been interpreted to mean that social media companies, ISPs, and other “online intermediaries” have not been subject to liability for their users’ actions.

On July 27, the Trump Administration—acting through the National Telecommunications and Information Administration—submitted a Petition for Rulemaking on Section 230, and Chairman Pai announced on August 3 that the FCC would seek public comment on the petition.  That petition asked the FCC to adopt rules to “clarify” the circumstances under which the liability shield of Section 230 applies.  Citing the FCC General Counsel’s reported position that the Commission has the legal authority to interpret Section 230, Chairman Pai today stated that a forthcoming agency rulemaking will strive to “clarify its meaning.”

Continue Reading FCC Announces Section 230 Rulemaking

Yesterday, the Federal Communications Commission (“FCC”) circulated a new Net Neutrality Order for consideration at its October meeting.  This draft Order on Remand does not mark a change in the FCC’s Net Neutrality policy; rather, it responds to several issues raised by the D.C. Circuit in Mozilla v. FCC, which reviewed the 2017 Restoring Internet Freedom Order.

The draft Order on Remand addresses the points raised by the D.C. Circuit in Mozilla but otherwise affirms the outcome of the Restoring Internet Freedom Order.  That Order rolled back Obama-era Net Neutrality regulations and largely deregulated broadband Internet service provider practices.

Continue Reading Order Responding to Net Neutrality Court Decision Circulated for Consideration at FCC’s October Meeting

Yesterday, the Federal Communications Commission (“FCC”) unanimously adopted an order formalizing the referral and review process associated with “Team Telecom”—the group of national security and law enforcement agencies responsible for assessing foreign investment in U.S. telecommunications, submarine cable licensees, and broadcast licensees. The order adopts rules and procedures that will govern what has long been an informal process at the agency, both in connection with the issuance of such licenses and with respect to transfers of control.

The FCC’s action is consistent with the agency’s increased focus on, and involvement in, questions around national security and foreign investment in the telecommunications and media sectors. This attention to national security at the FCC is likely to continue regardless of the outcome of the election in November, given that both Republicans and Democrats at the agency have supported the agency’s heightened role in national security matters under its jurisdiction.

Continue Reading FCC Formalizes Foreign Investment Reviews; More National Security Actions Likely to Follow

Last week, the Federal Communications Commission circulated a draft order that will formalize its coordination with what has been known as “Team Telecom”—the national security review process for foreign investments in U.S. telecommunications companies.  The draft order, which the FCC will consider for adoption at its September 30 Open Meeting, includes rules and procedures governing what has long been an informal process.

The FCC’s draft order adopts rules consistent with an April 4, 2020 Executive Order that rebranded the group of executive branch authorities long referred to as “Team Telecom” as the Committee for the Assessment of Foreign Participation in the United States Telecommunications Services Sector.  Despite the name change, Team Telecom will largely follow the existing review process; however, the new FCC rules do make a few key changes.  We highlight some of the basic changes below.

Continue Reading FCC Releases Draft Order Formalizing “Team Telecom” Process

Earlier this month, the Federal Communications Commission (“FCC”) asked for comment on a Petition for Rulemaking filed by the Consumer Technology Association (“CTA”) that proposes to modify the FCC’s device authorization rules to allow the importation and conditional, preauthorization marketing and sales of radiofrequency (“RF”) devices that have not yet been approved under the FCC’s rules.  The deadline for filing comments supporting or opposing the petition is July 9, 2020.
Continue Reading IoT Update: FCC Considering Changes to Device Rules

Yesterday, the Federal Communications Commission (“FCC”) granted GE Healthcare (“GEHC”) a waiver of its equipment authorization rules to allow for the importation, marketing, and operation of certain medical devices that have yet to receive authorization under applicable FCC requirements.  The GEHC devices at issue include bedside and wearable patient monitors; telemetry transmitters; antenna infrastructure; wireless sensors; diagnostic testing ECG analysis systems; mobile radiology equipment; and portable X-rays.

The FCC granted the waiver due to the “unprecedented strain” that the COVID-19 pandemic has placed on the U.S. healthcare system.  In doing so, the FCC recognized that GEHC now has to rely on alternative component suppliers to maintain a robust supply chain of devices, and that doing so has and will continue to require GEHC to pursue and secure new or modified equipment authorizations under the FCC’s rules.  By waiving these rules for a temporary period,  subject to certain conditions, the FCC enabled GEHC to import, market, and operate these devices before they are fully authorized, thereby improving the speed at which GEHC can bring them to market.
Continue Reading IoT Update: FCC Waives Equipment Authorization Rules for GE Healthcare to Address COVID-19 Supply Chain and Testing Challenges

In light of the COVID-19 pandemic, Congress and the Federal Communications Commission (FCC) have ramped up efforts to subsidize the provision of the telecommunications and broadband services necessary to deliver telehealth solutions.  This includes steps to make it easier for eligible health care providers to secure funding under the FCC’s existing Rural Healthcare (RHC) program, developing procedures for tapping into a new $200 million COVID-19 Telehealth Fund, and launching a pilot program intended to help eligible health care providers deliver online (connected) care to a greater number of low-income patients and veterans.
Continue Reading FCC Embarks on New Rural Health Initiatives with CARES Act Funding

Yesterday, the Federal Communications Commission (“FCC”) on its own motion released a Declaratory Ruling to confirm that the COVID-19 pandemic constitutes an “emergency” under the Telephone Consumer Protection Act (“TCPA”); as a consequence, hospitals, health care providers, state and local health officials, and other government officials may lawfully communicate through automated or prerecorded calls (which include text messages) information about the coronavirus and mitigation measures to mobile telephone numbers and certain other numbers (such as those of first responders) without “prior express consent.”

Continue Reading FCC Clarifies that COVID-19 “Emergency Purposes” Calls/Text are Not Subject to “Prior Express Consent” Requirement

Yesterday, the Federal Communications Commission sent a letter to an individual in Brooklyn, New York, alleging that a device in the individual’s residence that is being used to mine Bitcoin is generating spurious radiofrequency emissions, causing interference to a portion of T-Mobile’s mobile telephone and broadband network.

The letter states that on November 30, 2017,

Earlier today, the FCC placed on public notice two petitions requesting that the agency clarify or forbear from enforcing certain aspects of its new TCPA regulations that went into effect on October 16, 2013.  Those regulations, which we summarized here, created, among other things, a new “prior express written consent” requirement for the transmission