Cinnamon Mueller Client Updates

New Net Neutrality Rules Effective Next Monday, June 11th; All ISPs Should Update Their Transparency Disclosures

June 5, 2018 Rule changes adopted by the Restoring Internet Freedom Order (“RIF Order”) will go into effect June 11, 2018. In addition to returning Internet service providers (“ISPs”) to Title I classification, the RIF Order modifies the transparency rule, which requires ISPs to disclose certain network management practices. All ISPs should ensure that required transparency disclosures are accessible through a website or through the new database established by the Consumer and Government Affairs Bureau by Monday, June 11th.

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Restoring Internet Freedom Order Effective June 11th; FCC Establishes Portal for ISP Disclosures

May 22, 2018 Rule changes adopted by the Restoring Internet Freedom Order (“RIF Order”), more commonly known as the net neutrality rules, will go into effect June 11, 2018. In addition to returning Internet service providers (“ISPs”) to Title I classification, the RIF Order, which was adopted by the FCC on December 14, 2017, modifies the transparency rule, which requires ISPs to disclose certain network management practices. ISPs must also ensure that required transparency disclosures are accessible through a website or through the new database established by the Consumer and Government Affairs Bureau. The new database will be available beginning May 29, 2018.

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FCC Temporarily Freezes New Earth Station Applications, Announces 90-Day Window Registration Window for Operational, but Unregistered Stations

April 24, 2018 On April 19, 2018, the FCC’s Internal, Public Safety and Homeland Security and Wireless Telecommunications Bureaus (collectively, the “Bureaus”) released a Public Notice announcing a temporary freeze on the filing of new or modification applications for fixed-satellite service earth station licenses, receive-only earth station registrations and fixed microwave licenses in the 3.7-4.2 GHz frequency band. At the same time, the Bureaus opened a 90-day window during which entities that own or operate existing earth stations in the 3.7-4.2 GHz band may file an application to register or license the earth station if it is not currently registered or licensed.

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FCC Grants Petition to Remove Significantly Viewed Status of Stations in Two Pennsylvania Communities

April 11, 2018 On April 2, 2018, the FCC’s Media Bureau released an Order granting a broadcaster’s petition to remove the significantly viewed status of two stations in Lancaster and Elizabethtown, Pennsylvania. By demonstrating that the two stations were no longer significantly viewed, the cable operator(s) serving Lancaster and Elizabethtown will no longer be able to rely on the significantly viewed exception if the broadcaster attempts to exercise its network non-duplication and syndicated exclusivity rights against the cable operator(s). Importantly, no cable operator opposed the petition.

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FCC Form 499-A Due April 2, 2018

March 28, 2018 All providers of telecommunications, including resellers and those offering interconnected VoIP service, with very limited exceptions, must file their annual telecommunications revenue report (Form 499-A) on or before April 2, 2018. This includes any entity that relies on the de minimis exception for contributions to the federal Universal Service Fund (“USF”).

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Accessibility Recordkeeping Compliance Certification Due April 2, 2018

March 6, 2018 On March 1, 2018, the FCC released a Public Notice reminding telecommunications carriers, interconnected VoIP and advanced communications service (“ACS”) providers that they must file their annual accessibility compliance certificate (covering 2017) by April 2, 2018. This certificate certifies that the provider has operating procedures in place to ensure compliance with the recordkeeping requirements contained within the FCC’s rules adopted in accordance with the 21st Century Communications and Video Accessibility Act (“CVAA”) of 2010.

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