The FCC this week released its second EEO audit notice for 2023.  The FCC’s Public Notice, audit letter, and the list of stations selected for audit is available here.  Those stations, and the station employment units (commonly owned or controlled stations serving the same area sharing at least one employee) with which they are associated, must provide to the FCC (by uploading the information to their online public inspection file) their last two years of EEO Annual Public File reports, as well as backing data to show that the station in fact did everything that was required under the FCC rules.  The response to this audit is due to be uploaded to the public file of affected stations by December 14, 2023. The audit notice says that stations audited in 2021 or 2022, or whose license renewals were filed after October 1, 2021, can ask the FCC for further instructions, possibly exempting them from the audit because of the recent FCC review of their performance.  Perhaps for this reason, no stations in New England or the Mid-Atlantic (NY, NJ, PA, and DE) states, are included in the list of audited stations, as stations in these states were the last to file their license renewals.

With the release of this audit, and the recent $25,000 fine proposed for some Kansas radio stations that had not fully met their EEO obligations (see our article here), it is important to review your EEO compliance even if your stations are not subject to this audit.  The FCC has promised to randomly audit approximately 5% of all broadcast stations each year. As the response (and the audit letter itself) must be uploaded to the public file, it can be reviewed not only by the FCC, but also by anyone else with an internet connection anywhere, at any time.  The recent proposed fine, a fine imposed on Cumulus Media for a late upload of a single EEO Annual Public File Report last year (see our article here), and the FCC’s pending consideration of the return of the EEO Form 395 reporting on the race and gender of all station employees (see our article here), shows how seriously the FCC takes EEO obligations.

Continue Reading FCC Announces Second EEO Audit of 2023 – 150 Radio and TV Stations Must Report on Their EEO Compliance

Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.

  • The FCC’s Wireless Telecommunications Bureau announced that comments responding to the Bureau’s proposed final deadlines for the submission of reimbursement claims by earth station operators affected by the C-band transition are due by November 8, 2023.  As we reported in last week’s update, the Bureau has proposed the following deadlines for the submission of C-band transition reimbursement claims:
    • February 5, 2024 – Deadline for submission of all reimbursement claims for costs incurred and paid by claimants as of December 31, 2023, including all lump sum election claims by incumbent earth station operations.
    • September 30, 2024 – Deadline for submission of all reimbursement claims for costs incurred and paid by claimants after December 31, 2023, which must be submitted on a rolling basis within 30 days of being incurred.
  • The FCC’s Media Bureau granted an FM translator’s minor modification application to relocate to a new transmitter site and to specify a new primary station.  The Bureau rejected an objection arguing that the move violated a condition on all translator licenses that construction pursuant to a construction permit not be with “temporary” facilities and that translators not excessively “hop” over significant distances (using a series of rapid minor changes to move a station a significant distance – a move that should wait for a major change window where the application could be subject to competing applications).  The translator’s licensee had recently purchased the translator and filed for Special Temporary Authority to cease operations while it prepared for the site relocation.  The licensee demonstrated through documentation (included dated photos, emails, invoices, and a sworn declaration of its consulting engineer) that the translator’s initial facilities had been fully constructed for permanent operations and the translator could have operated from those facilities for the foreseeable future.  As the licensee had a legitimate business purpose for the move (so that it could rebroadcast the new primary station), the Bureau found that the construction was not temporary construction prohibited by the FCC’s policies.  The policy against temporary construction instead focuses on the use of short-term facilities (like a tower on a flatbed truck that operates for only a matter of days, with no long-term commitment to use the site from which the operation is commenced), usually to meet the construction deadlines or where there are rapid sequential moves to try to move the station over a significant distance.  This policy has also been applied to LPTV stations. For more on these policies and the harms that they seek to prevent, see our Broadcast Law Blog articles here and here. 
  • The FCC’s Public Safety and Homeland Security Bureau announced the agenda for its upcoming October 30 roundtable on the cybersecurity of the nation’s public alert and warning systems.  As we noted in last week’s update, the roundtable will include a discussion among public and private sector representatives to build upon the FCC’s October 2022 Notice of Proposed Rulemaking – which proposes measures to enhance cybersecurity and operational readiness of the Wireless Emergency Alerts and the Emergency Alert System, including mandatory cybersecurity programs at all broadcast stations as well as regular reports to the FCC by broadcasters on their cybersecurity programs.  The event will include remarks by FCC Chairwoman Rosenworcel and representatives of the Cybersecurity and Infrastructure Security Agency, which is co-hosting the event.  Registration is free and open to the public.  Interested participants may register here for the event.
  • The FCC’s Media Bureau issued an Order to Pay or to Show Cause to the licensee of  a Louisiana AM and FM combination, proposing to revoke the stations’ licenses unless, within 60 days, the licensee pays delinquent regulatory fees and interest, administrative costs, and penalties.  According to the Order, the FCC’s records indicate that the stations currently have unpaid regulatory fee debt for the AM Station totaling $12,098.17 (debts due from fiscal years 2002, 2012, 2013, 2014, 2015, 2016, 2017, 2018, 2019, and 2022) and, for the FM station, $8,906.97 from 2002, 2012, 2013, 2014, 2015, 2016, 2017, 2019, and 2022. 
  • On our Broadcast Law Blog, we published our look ahead to the regulatory dates of interest to broadcasters in November and early December.

November is a month where there are no regularly scheduled regulatory deadlines.  But the big question for broadcasters may be whether the FCC will continue to function throughout the month. The last-minute continuing resolution passed by Congress on September 30 extended federal government funding through November 17 – which again raises the possibility of a federal government shutdown beginning in late November if Congress does not approve new funding measures for Fiscal Year 2024 by that date.  As we discussed in our previous article regarding October Regulatory Dates for Broadcasters, if a government shutdown does occur, the FCC and other government agencies may have to cease all but critical functions if they do not have any residual funds to continue operations.  In late September, the FCC announced that it had sufficient leftover funds to keep operating for about two weeks after a shutdown.  We do not know if those funds are still available, so we need to be watching to see what happens between now and November 17.

Assuming that there is no shutdown, there are a number of other dates that broadcasters should be watching.  All broadcasters need to remember that November 20 is the deadline to file their ETRS Form Three to provide more detailed information regarding their stations’ performance during the October 4 Nationwide EAS Test.  See our article here regarding this year’s EAS test and broadcasters’ reporting obligations.  This deadline is important for many reasons – not just to avoid potential penalties for missing the filing deadline, but also to demonstrate broadcasters’ commitment to the emergency communications system as broadcasters’ role in that system is the principal reason for Congress to be presently considering the bill to require AM radio in every car.  See our article here for more on the importance of accurate reporting. 

Continue Reading November Regulatory Dates for Broadcasters – EAS ETRS Form 3, 12.5 GHz Registrations, C-Band Transition Comment Deadline, a Possible Government Shutdown, and More

Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.

  • The FCC’s Enforcement Bureau released a Notice of Apparent Liability proposing a $25,000 fine on two commonly-owned clusters of broadcast stations for their apparent failure to comply with the FCC’s EEO rules.  The proposed fine was based on two EEO Annual Public File Reports at one cluster being uploaded late (one 5 months late, the other 17 months late) and one Annual Report at the other cluster being uploaded over a year late.  The FCC also found that, in two cases, the stations had not publicized job openings in a manner likely reach the entire community served by the stations, as the rule requiring that broadcasters “widely disseminate” information about job openings requires – relying solely on a recommendation from a departing employee in one case, and on the licensee’s on-air announcements on its own stations in the other.  The Bureau also faulted the broadcaster for not keeping adequate paperwork to document its EEO efforts and for not conducting the kind of required “self-assessment” that would have uncovered the issues.  We wrote more on this decision, and whether it signals more robust EEO enforcement in the future, on our Broadcast Law Blog, here.
  • The FCC’s Media Bureau issued a Public Notice extending the scheduled window for filing applications for new Low Power FM stations from early November until December.  The LPFM Filing window will now open at 12:01 am EST on December 6, and close at 6:00 pm EST on December 13.  The Bureau also extended the freeze on LPFM and FM translator minor modification applications until the close of the filing window on December 13.  For more on the extension and the procedures for filing applications in the window, see our Blog article here. 
  • The FCC’s Wireless Telecommunications Bureau issued a Public Notice seeking comment on the proposed deadlines for the submission of reimbursement claims by earth station operators affected by the C-band transition.  The goal is to conclude the reimbursement program by the current target of June 30, 2025.  Comments will be due 15 days after the Public Notice is published in the Federal Register on the following proposed deadlines: 
    • February 5, 2024 – For all reimbursement claims for costs incurred and paid by claimants as of December 31, 2023, including all lump sum election claims by incumbent earth station operations.
    • September 30, 2024 – For all reimbursement claims for costs incurred and paid by claimants after December 31, 2023, which must be submitted on a rolling basis within 30 days of being incurred.
  • The FCC’s Public Safety and Homeland Security Bureau issued a Public Notice announcing that it will co-host with the Cybersecurity and Infrastructure Security Agency’s Emergency Communications Division a public roundtable on the security of the nation’s public alert and warning systems, including EAS.  The roundtable is scheduled for 9:30 am EDT on October 30 and will include a discussion among representatives of the government and private industry on issues raised in the FCC’s October 2022 Notice of Proposed Rulemaking, which proposed, among other things, mandatory cybersecurity programs at all broadcast stations as well as regular reports to the FCC by broadcasters on their programs.  The roundtable will focus on the costs and benefits of these proposals.  We wrote about the FCC’s October 2022 NPRM here.  Registration is free and open to the public.  Interested participants may register here for the event.
  • The FCC issued an Order expanding the FCC’s audio description requirements to commercial broadcast television stations affiliated with one of the top four television broadcast networks (i.e., ABC, CBS, Fox, and NBC) in Designated Market Areas 101-210.  Currently, the FCC’s audio description requirements apply only to the top 90 DMAs and will be extended to DMAs 91-100 as of January 1, 2024.  As a result of the FCC’s Order, the audio description requirements will now expand to DMAs 101-210 beginning with DMAs 101-110 on January 1, 2025, and ending with DMAs 201-210 on January 1, 2035.  Audio description provides narrated descriptions of a television program’s key visual elements during natural pauses in the program’s dialogue, for the benefit of individuals who are blind or visually impaired.  Covered TV stations must pass through 87.5 hours of audio described programs each calendar quarter.
  • The Media Bureau allotted new television channels reserved for noncommercial operations in the following communities: Tulare, California (channel *3), Colusa, California (channel *2), and Alamogordo, New Mexico (channel *4). It also allotted FM Channel 277C2 at Wharton, Texas.  Applications for new stations on these newly allotted channels can be filed during windows that will be announced in the future.  The Media Bureau also granted the request of an existing TV station in Las Vegas to move to UHF channel 26 instead of its current VHF channel 13, reflecting the perceived superiority of UHF channels for digital operations.

On our Broadcast Law Blog, we published an article warning broadcasters of the trademark issues that can arise from the use of the words “World Series” in any baseball themed advertising or promotions without permission of Major League Baseball. 

Earlier this week, the FCC’s Enforcement Bureau issued a Notice of Apparent Liability proposing a $25,000 fine on two related companies operating clusters of stations in two small Kansas markets.  Those clusters have, because of financial setbacks (leading to bankruptcy), reduced staff so that they no longer have 5 full-time employees at either cluster and thus are no longer subject to the FCC’s EEO outreach requirements. In this Notice, the FCC staff looked back to a few isolated violations in 2020 and 2021, when the stations had 5 or more full-time employees, to justify the proposed $25,000 fine.

The Enforcement Bureau pointed to the late upload to the online public file of three Annual EEO Public File Reports. The Bureau also pointed to the late upload of two Annual EEO Public File Reports at one of the clusters, and one late upload at the other cluster.  Both the 2020 and 2021 reports for one cluster were uploaded in June 2021, when the reports were due in February of each year.  Thus, one report was 5 months late, the other 17 months late.  At the other cluster, the 2021 report was uploaded a year late.  There was no allegation that the reports were not completed on time – just that they were not timely uploaded.

Continue Reading $25,000 Proposed Fine for Alleged EEO Violations at Kansas Radio Clusters – A Higher Standard for FCC EEO Enforcement?

The FCC yesterday issued a Public Notice announcing that it was rescheduling the filing window for new Low Power FM stations that had been scheduled for early November – moving the window to December.  Applications now can be filed between 12:01 AM Eastern Time on December 6, 2023 and 6:00 PM ET on December 13, 2023.  The FCC stated that a group of low power advocates had requested the extension to give applicants more time to prepare their applications.  The FCC warns in the Public Notice that this deadline will be strictly enforced – so don’t expect any leniency for any application that does not meet the 6 PM deadline on December 13.

Note that this extension also extends the freeze that the FCC imposed on LPFM and FM translator minor modifications.  That freeze, imposed to provide LPFM applicants with a static database from which to work in planning their applications, will now run through December 13.

Continue Reading FCC Postpones LPFM Filing Window and Extends Filing Freeze – Application Filing Window Now December 6 through December 13

Readers of the Broadcast Law Blog are familiar with the potential trademark claims that may arise from the use of SUPER BOWL® (see here) or FINAL FOUR® in advertising or promotions (see here and here).  I was recently asked, in light of the various “WORLD SERIES OF ____” marks that are being used for sports or activities other than baseball, whether there is a similar risk with using WORLD SERIES® in advertising or promotions during this time of year.

The short answer is yes.

The first use of “World Series” for the US professional sports championship took place in 1903, if not earlier.  However, it was not until 1987 that the Office of the Commissioner of Baseball (“MLB”) began seeking federal registration for “World Series” trademarks.  The applications were based on use of the marks before 1986.  (Use of a trademark without registration can create “common law” marks, which are enforceable, but the owner of the mark does not have the presumptions of ownership and validity that accompany trademarks registered on the Principal Register of the US Patent and Trademark Office.)

Today, MLB owns a number of registered marks for “WORLD SERIES” in words, in a stylized format or with a design.  MLB’s rights in “WORLD SERIES” marks are strong.  Indeed, MLB appears to own all of the registrations for WORLD SERIES-formative marks for goods or services relating to baseball tournaments and merchandise, including COLLEGE WORLD SERIES®, WOMEN’S COLLEGE WORLD SERIES® and HIGH SCHOOL WORLD SERIES®, notwithstanding the fact that those events are run by the NCAA or other sports organizations.  (see here and here).  Although it is probably not obvious to the average fan, MLB owns these marks and licenses the respective trademarks to the actual tournament operators.  The fact that MLB has made these arrangements reflects how seriously MLB takes protecting its WORLD SERIES® mark and how strong those rights are – up to a point.

Continue Reading Unauthorized Use of WORLD SERIES in Advertising or Promotions?  Strike One, Strike Two … !!

Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.

  • FCC Chairwoman Rosenworcel announced that two Notices of Proposed Rulemaking (NPRMs) have been drafted, which, if adopted by the Commission, would seek public comment on proposals to protect consumers from the effects of blackouts lasting more than 24 hours resulting from the failure of broadcasters and Multichannel Video Programming Distributors (MVPDs, i.e., cable and satellite TV providers) to reach a retransmission consent agreement.  The NPRMs propose to require MVPDs, in the event of a blackout due to the failure to reach a retransmission consent agreement with a broadcaster, to: (1) issue rebates to subscribers to compensate them for the channels that they do not receive; and (2) notify the Commission via an online public portal of broadcast blackouts lasting 24 hours or more. These specifics of the proposed NPRMs have been circulated to the other Commissioners for their review and are not yet publicly available. 
  • The FCC imposed two substantial fines on pirate radio operators who ignored FCC warnings to cease their operations.  In each case, the pirate radio operators have 30 days to pay the fine or their case will be referred by the Commission to the U.S. Department of Justice for enforcement.  The FCC itself cannot sue to collect fines against individuals who ignore the penalties issued in cases like this; instead, it relies on the DOJ to enforce the penalties in Court.  The specifics of these cases follow:
    • In one case, the Commission imposed a $2,316,034 fine against two individuals for operating a pirate FM radio station in Queens, New York.  The decision followed the Commission’s March 2023 Notice of Apparent Liability, which we wrote about here, when the FCC first proposed the fine.  The two individuals failed to respond to its March 2023 Notice.  The Commission relied upon the PIRATE Act passed by Congress in 2020, which enabled the FCC to impose higher fines for pirate radio operators.  The Commission concluded that the maximum penalty under the PIRATE Act was appropriate because the pirate radio operators operated their pirate radio station for over a decade – even after many prior FCC actions including repeated warning (including personal warnings by FCC agents), previous fines that were ignored, and equipment seizure by US Marshalls.  Despite all these actions, the pirate continue to operate, even promoting their operations on a website and through social media. 
    • In the second case, also an Order following up on a March Notice of Apparent Liability (which we also wrote about here), the FCC imposed an $80,000 fine on the operator of an Oregon pirate station.  This pirate also failed to respond to the FCC’s March Notice of the proposed fine.  In the Oregon case, the pirate kept operating despite repeated warnings from the FCC and twice having his equipment seized by the Federal government.  The pirate apparently ceased operations only when his landowner was threatened by the FCC with a fine (under the PIRATE Act, landowners can be fined for allowing pirates to operate from their land).
  • Last week, the FTC held a roundtable discussion on the creative economy and generative artificial intelligence (“AI”).  The event featured remarks from FTC Chair Lina Khan, FTC Commissioner Rebecca Kelly Slaughter, and FTC Commissioner Alvaro Bedoya – which was followed by a discussion with stakeholders representing creative media organizations.  Each witness expressed concern about how AI could affect their industry by appropriating their work to create new content that the original artists are not compensated for and did not consent to.  More information, including transcripts and video of the proceeding, are available on the FTC website here.
    • The potential harms of generative AI was also addressed by Congress this week through the introduction of a bipartisan bill, which seeks to protect actors, musicians, and other performers’ likenesses from unauthorized replicas that are generated using AI.  Specifically, under the bill, known as the Nurture Originals, Foster Art, and Keep Entertainment Safe (NO FAKES) Act, individuals and companies would be held liable for producing unauthorized replicas of individuals’ performances generated using AI.  The bill, however, exempts from liability certain AI replicas: (1) used as part of a news, public affairs, or sports broadcast or report; (2) used as part of a documentary, docudrama, or historical or biographical work; (3) used as part of scholarship, satire, or parody; and (4) where the use of the AI replica is de minimis or incidental. 
  • The FCC’s Media Bureau proposed a $13,000 fine against the licensee of two TV translator stations for failing to timely file license applications for the translators and operating the stations without authorization after their construction permits had expired.  The translators’ licensee admitted that, due to a misunderstanding with its former consulting engineer, it failed to file license applications for the translators when their construction was completed, and it continued operating the translators after their construction permits had expired.  The FCC’s rules normally require a base fine of $3,000 for failing to timely file a license application, and a base fine of $10,000 for operating a station without proper authorization.  In this case, however, the Bureau reduced the proposed fine from $13,000 to $6,500 for each station because TV translator stations are secondary services.  Nevertheless, the Bureau noted that while other TV translators were previously fined only $3,500 for similar violations, a greater fine of $6,500 was warranted here because the translators engaged in unauthorized operations for far longer than in the previous cases.  Finally, the Bureau reinstated the translators’ construction permits (thereby enabling their license applications to be granted) based upon the Bureau’s practice of reinstating permits when a licensee has failed to timely file a license application for a station but clearly completed construction of the station before the station’s permit had expired.

While this week was light on regulatory activity at the FCC, the Commission is slated to consider a draft order next week at its October 19 Open Meeting.  If the order is adopted, the FCC’s audio description requirements would expand to commercial broadcast television stations affiliated with one of the top four television broadcast networks (i.e., ABC, CBS, Fox, and NBC) in Designated Market Areas (DMAs) 101 through 210 at a rate of 10 additional DMAs per year.  We’ll provide more information on that item next week.

Here are some of the regulatory developments of significance to broadcasters from the past week, with links to where you can go to find more information as to how these actions may affect your operations.

  • The re-nominations of FCC Commissioners Geoffrey Starks and Brendan Carr were approved by the Senate late the week before last (see Starks and Carr statements on Senate approval).  Starks’ term expired at the end of 2022, but Commissioners are allowed by the Communications Act to hold over for a year if no successor has been approved, so he could have served through the end of 2023.  Now that his renomination has been approved by the Senate, he can serve through 2027.  Carr’s term was to end this year, and he has now been approved to serve through 2028.  With the recent approval of the nomination of Anna Gomez to fill the long vacant fifth seat on the Commission, the FCC (barring the early departure of one of the Commissioners) will have its full complement of Commissioners at least through next year’s presidential election.  See our Broadcast Law Blog article here on some of the broadcast issues that the now full Commission may now tackle.
  • The Nationwide Test of the EAS system was conducted on Wednesday, October 4.  Just before the test, the FCC and FEMA issued a News Release reminding the public about the test and reminding broadcasters planning news reports about the test to avoid using the EAS alert tones during their newscasts.  The use of the EAS tones outside actual tests is prohibited.  All licensees should have filed ETRS Form Two by the end of the day on October 5, reporting whether the test was received, and they must file Form Three by November 20 providing more information about the results of the test.  
  • The FCC released its quarterly Broadcast Station Totals Press Release.  The release shows that, compared to the same release from a year ago, there are 38 fewer AM stations, and 7 fewer FM stations, but 55 more noncommercial FM stations. There were single digit increases in UHF television stations, while VHF stations decreased by a similar amount.
  • The FCC’s Media Bureau continued to address proposed changes to the TV Table of Allotments.  Once the repacking of the TV band following the incentive auction was complete, the FCC in 2021 lifted the freeze that had been imposed on changes to the Table, allowing TV stations to propose channel changes for existing stations, and others to ask for allotments for new TV stations.  This week, the FCC’s Media Bureau took two such actions:
    • It issued a Report and Order substituting UHF channel 21 for VHF channel 7 at Knoxville, Tennessee, to address signal receptions suffered by the channel 7 licensee, continuing the move of TV stations from VHF to UHF channels which are superior for reception of digital signals. 
    • The Bureau also requested comment on a proposal submitted by the permittee of an unbuilt television station on channel 31 at Wittenberg, Wisconsin, to reallocate the channel to Shawano, Wisconsin, and modify the proponent’s  construction permit to specify Shawano as its community of license.  The FCC may modify a station’s community of license without affording other interested parties an opportunity to file competing expressions of interest, provided that the new allotment (1) will be mutually exclusive with the proposing station’s existing allotment; (2) will result in a preferential arrangement of the allotments according to the FCC’s television allotment priorities; and (3) will not deprive a community of its sole local transmission outlet.  As to criterion (3), the Wittenberg proponent argued that Wittenberg would not lose any existing service because its station has not commenced operations, and thus no viewers have come to rely on the station for television service.  The Wittenberg proponent also contends that providing Shawano (a community nine times larger than Wittenberg) with its first local television service is the type of “rare circumstance” which justifies a waiver of the general prohibition on the removal of a community’s sole first local service. 
  • In re-evaluating three mutually exclusive applications from the 2021 window for new NCE FM stations, , the Media Bureau dismissed the application that had previously been preferred for a construction permit at St. Michaels, Arizona because of that applicant’s failure to comply with the FCC’s “signature rule,” and sent the remaining two applications to the full Commission to conduct a second comparison under its points system analysis. Under the “signature rule,” an application filed by a corporation must be signed by an officer or director.  The signatory to the dismissed applicant’s application was its general manager, who was neither an officer nor a director of the company.  The Bureau ruled that the FCC’s rules did not permit the dismissed applicant to cure this defect by amending its application.

Last week, as we noted in our weekly summary of regulatory actions of importance to broadcasters, the US Court of Appeals for the D.C. Circuit issued an Order directing the FCC to complete its 2018 Quadrennial Regulatory Review of its broadcast ownership rules by December 27, 2023, or show cause why the National Association of Broadcasters’s (NAB) Petition for Writ of Mandamus should not be granted.  The NAB’s petition, filed in April 2023, requests that the D.C. Circuit compel the FCC to conclude the agency’s still-pending 2018 review.  Neither last week’s order, nor any mandamus order that could be issued by the Court should the FCC fail to finish its review by December 27, will compel any particular decision.  Instead, such an order would only require that the FCC finish the review started in 2018 (see our article here on the start of that review process).

The Quadrennial Review process is mandated by Congress.  Every four years, the FCC is required to review its local ownership rules and determine which ones remain in the public interest.  The NAB’s argument to the Court has been that the FCC failed to meet its statutory obligation by not completing the 2018 review last year.  In December, we wrote about the FCC’s failure to complete the Quadrennial Review, and how the inaction has forestalled any review of the issues that were teed up in that review.  What were those issues?

Continue Reading Court Orders FCC to Complete Quadrennial Review by December 27 – What are the Issues for Review by the Commission?