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FCC’s Second Further Notice of Proposed Rulemaking on Reassigned Numbers Published in Federal Register; Comment Clock Begins

On March 22, 2018, the FCC adopted a Second Further Notice of Proposed Rulemaking (FNPRM) on reassigned numbers. On April 23, 2018, the FNPRM was published in the Federal Register, triggering the commenting period deadlines. Comments on the FNPRM must be submitted by June 7, and reply comments must be submitted by July 9, 2018.

The version of the FNPRM adopted last month is largely the same as the draft document summarized here. However, it adds language seeking comment on the effect of the ACA International ruling (which we covered here) on reassigned number safe harbors, as well as detailed proposals on which types of calls would be covered by any such safe harbor. It also asks whether the ruling strengthens the need for a comprehensive database or instead suggests that existing commercial databases might be sufficient as resources for discovering number reassignment.

The FNPRM also contains short statements from each of the Republican FCC Commissioners and Democratic Commissioner Jessica Rosenworcel. Republican Mike O’Rielly notably suggests that the ACA International ruling may present an opportunity to reopen a wide range of TCPA issues beyond just those directly implicated by the ruling.

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Laura Phillips, Drinker Biddle Law Firm, Washington DC, Communications Law Attorney
Partner

Laura H. Phillips is a partner in and chair of the firm's Government & Regulatory Affairs Practice Group and a member of the Telecommunications & Mass Media Team.  She has over 25 years of experience working in nearly every aspect of the telecommunications market.

Laura counsels wireless and wired technology entrepreneurs and represents these clients on issues related to the development of new technologies, including devoting substantive attention to the development of spectrum auctions, network...

202-842-8891
Michael Daly, Drinker Biddle Law Firm, Philadelphia, Litigation and Retail Attorney
Partner

Michael P. Daly defends class actions and other complex litigation matters, handles appeals in state and federal courts across the country, and counsels clients on maximizing the defensibility of their marketing and enforceability of their contracts. A recognized authority on class action and consumer protection litigation, he often speaks, comments, and writes on recent decisions and developments in the class action arena. He is also a founder of the firm’s TCPA Team; the senior editor of the TCPA Blog, which provides important information and insight about the Telephone Consumer Protection Act; and a senior member of the firm's Class Actions Team and interdisciplinary Retail Industry Team.

Committed to civil rights and civic engagement, Michael has spearheaded public interest matters meant to prevent racial discrimination, protect the rights of the disabled and incarcerated, prohibit the use of unverifiable voting systems, and preclude the misuse of our laws and abuse of our civil justice system. One of his most recent public interest matters resulted in a landmark settlement that put an end to decades of discrimination by administrative agencies that had refused to make important information about public benefits programs available in alternative formats that were accessible to the blind and visually impaired. As a result of the settlement, thousands of class members have already requested and received documents in accessible alternative formats.

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Anthony Glosson, Drinker Biddle, Privacy & Communications Lawyer
Associate

Anthony D. Glosson assists clients with a range of privacy, communications, and regulatory compliance matters. He is the author of several publications in the field of technology law, and has been selected as a keynote speaker for a Capitol Hill discussion on active cyber defense.

Prior to joining Drinker Biddle, Anthony worked on numerous privacy and communications matters while serving as a law clerk for FCC Commissioner Ajit Pai, technology advocacy group TechFreedom, and state policy forum American Legislative Exchange...

(202) 230-5131