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Elfin Noce

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Elfin Noce is an associate in the Intellectual Property Practice Group in the firm's Washington, D.C. office. He also is a member of the Privacy and Cybersecurity Team.

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Key Takeaways:  The Federal Communications Commission (“FCC”) sent a resounding message to the telecommunications industry: the era of lax CPNI enforcement is over.  

  • Mobile network operators (MNOs), mobile virtual network operators, Internet Service Providers, and Voice-Over-IP providers, and other operators subject to the FCC’s CPNI rules should be aware of the FCC’s expansive view on the kinds of data subject to the CPNI rules.

Continue Reading Dialing Up Accountability: FCC’s Warning Shot to Mobile Network Operators on CPNI

On November 16, 2023, the Federal Communications Commission (“FCC”) released a Report & Order (“Order”) and Further Notice of Proposed Rulemaking (“FNPRM”), adopting measures to address two techniques bad actors frequently use to access victims’ cell phone accounts: (1) SIM swapping and (2) port-out fraud.Continue Reading Shutting Down the Cell Phone Scammers: The FCC Adopts Rules to Crack Down on Fraudulent Practices against Wireless Phone Users

Recently, the FCC reminded telecom providers that the cost of failing to protect their customers’ privacy is steep. In a July 28, 2023 Notice of Apparent Liability for Forfeiture, the Federal Communications Commission fined Q Link Wireless LLC and Hello Mobile Telecom LLC, an affiliate of Q Link, $20 million for impermissibly relying upon readily available biographical information and account information to authenticate online customers.[1]Continue Reading ALERT: The FCC Fines Companies $20 Million for Failing to Safeguard Customer Proprietary Network Information

On August 12, 2020, a Ninth Circuit panel affirmed three orders issued in 2018 by the Federal Communications Commission (FCC) to promote infrastructure investment and broadband deployment, including 5G small cell nodes.
Continue Reading Ninth Circuit Rejects Challenges to FCC’s One-Touch Make-Ready, Small Cell Deployment, and Local Moratoria Orders

Maine entered the privacy fray last week when Governor Janet T. Mills signed legislation targeting internet service providers by prohibiting the sale of information about customers’ internet use. The new restriction covers, in part, customer web browsing history, application usage history, and geolocation information. An internet service provider may only use, disclose, sell or permit access to such information with either the customer’s consent or by complying with one of the few outlined exceptions in the statute.
Continue Reading Maine Passes Broadband Privacy Bill