Congressional Report
Suggests Taxing Internet Services to Subsidize Phone Service |
2/11. The General Accounting
Office (GAO) released a report [PDF]
titled "Telecommunications: Federal and State Universal
Service Programs and Challenges to Funding". The report
provides an in depth review of existing universal service
programs. It also offers the suggestion that providers of
various Internet services be taxed to subsidize the
government's universal service programs.
The report states that "The last decade has seen a rapid
increase in the use of digital technologies and Internet
Protocol (IP) networks for communications. Applications now
exist to convert traditional analog voice services to digital,
to break the digital voice into ``packets,´´ and to send the
voice packets over the Internet or other IP networks. However,
under the current regulatory structure, providers of these IP
voice services do not have to contribute to the Universal
Service Fund for the IP voice services. Therefore, as these
new voice services gain popularity, concerns exist of whether
federal funding levels for universal service might eventually
decline. In addition, there is much debate about whether the
current federal regulatory framework for funding universal
service -- with its reliance on interstate telecommunications
revenues -- is appropriate for digital communications, where
voice, video, and data are carried in the same manner over
networks that lack intrastate/ interstate designations."
The report also states that "funding for federal
universal service generally comes from providers of interstate
``telecommunications services,´´ but may also be assessed
upon other providers of interstate telecommunications if the
public interest so requires. IP telephony is an application
that has, to date, been treated in effect as an ``information
service.´´ Therefore, companies offering IP telephony are
not currently required to make contributions to the universal
service fund from revenues for IP telephony services. As the
deployment of IP telephony technologies moves forward, and
more businesses and consumers begin to substitute IP telephony
for traditional telephone service, the question arises as to
whether a decline in the funding for universal service could
result."
The report continues that "Whether Congress and FCC
should continue to rely largely on providers of interstate
telecommunications services for the funding of federal
universal service is an increasingly important debate as the
world continues to migrate to digital communications
technologies and IP networks."
The report concedes that "the Communications Act was
originally structured and remains a ``stovepiped,´´ or
compartmentalized, law in which particular communications
services are governed under particular provisions of the law.
The resulting regulatory structure holds different types of
networks to different rules -- even when they are used to
provide similar services. Fundamentally, universal service
funding has been carried out under laws and regulations
pertaining to "telecommunications services." "
The report asserts that "It is unclear what rules should
apply for voice applications that could be defined as
``information services,´´ or more importantly, whether such
service distinctions should remain. We previously noted that
policymakers may face challenges in deciding how, under the
present structure of communications law, functionally similar
services are governed over different networks. IP telephony
and its effect on universal service funding is another example
of this increasing dilemma."
The report was prepared at the request of Rep. Ed Markey (D-MA),
the ranking Democrat on the House Commerce Committee's
Telecom Subcommittee, which oversees the FCC. The report's
lead author is Peter Guerrero. Rep. Markey is a liberal
Democrat who often favors a regulatory approach to
telecommunications issues. However, many other members of the
House Commerce Committee would likely oppose any efforts to
tax Internet services for universal service purposes. In
contrast, the Senate, which over represents sparsely populated
plains and western states, has a much larger concentration of
universal service enthusiasts. |
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GAO Report Reopens Debate
Over IP Telephony and Phone Subsidies |
2/11. The just released GAO report
[PDF] reopens a debate over the future of the FCC's universal
service programs. Various Congressional and other fora
discussed this issue often in the late 1990s. However,
Internet Protocol (IP) telephony and universal service have
been little debated in recent years. At issue is whether or
not, and if so, to what extent, communications services
provided by new Internet based technologies, such as IP
telephony, will be subjected to the cross subsidization and
regulation model now applied to telecommunications services
provided by the old analog phone technologies.
The Federal Communications
Commission (FCC) and its subsidiary corporations run a
collection of cross subsidization programs for the purpose of
making telecommunications services more available in high cost
and low income areas. Economists have long debated the
effectiveness of these programs. However, they are strongly
backed by legislators from rural states and districts. Also,
the more recently developed e-rate program provides
telecommunications services, computer networking, and Internet
services to schools and libraries under the rubric of
universal service. Under the various universal service
programs, business customers subsidize residential customers,
urban customers subsidize rural customers, and all phone
customers subsidize schools and libraries.
Section
254(d) of the Telecom Act of 1996 defines the obligation
to contribute to universal service programs. It provides that
"Every telecommunications carrier that provides
interstate telecommunications services shall contribute, on an
equitable and nondiscriminatory basis, to the specific,
predictable, and sufficient mechanisms established by the
Commission to preserve and advance universal service."
The statute does not require other regulated communications
industries, such as cable and broadcasting, to contribute. Nor
is the unregulated Internet industry required to contribute.
Administering the universal service system was complex when
there was just one giant Bell monopoly. It became a vastly
more difficult task for the FCC, and its various corporations
and boards following divestiture, with the emergence multiple
regulated telecommunications companies. Now, it is becoming
increasing impossible in a open competitive environment in
which a variety of competing technologies are used by people
to communicate with each other.
Congressional backers of universal service cross subsidies
have argued that unregulated and untaxed IP telephony services
might replace the old fashioned analog public switched
telephone network. Hence, they fear that their revenue pool
might dry up. To make universal service programs work, the FCC
needs a huge pool of revenue to tap. If businesses and
consumers switch to IP telephony services, and the FCC and
Congress still want to subsidize communications services, then
the FCC would need to obtain revenues from some other source,
such as IP telephony, other Internet services, or the general
fund. |
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People and Appointments |
2/11. The Senate confirmed Michael Melloy to be a
Judge on the U.S. Court
of Appeals (8thCir) by a vote of 91 to 0.
2/11. The Internet Corporation
for Assigned Names and Numbers (ICANN) announced the
appointment of Stephen Crocker as chair of its newly
formed Standing Committee on Security and Stability, which
will focus on the security of the Internet's naming and
address allocation systems. See, ICANN
release.
2/11. Terry Hungle, Chief Financial Officer of Nortel Networks,
resigned. Nortel stated in a release
that "The U.S. Securities and Exchange Commission and the
Ontario Securities Commission have been voluntarily notified
of the circumstances surrounding certain personal investment
transactions carried out in 2001 by Hungle in the Nortel
Networks U.S. Long-Term Investment (401k) Plan. These
transactions occurred outside the trading windows imposed by
the Corporation upon certain employees, including Hungle, and
prior to news releases issued by the Corporation on March 27,
2001 and December 21, 2001." Frank Dunn, P/CEO of
Nortel, was appointed acting CFO. Dunn stated in the Nortel
release that "this matter solely relates to the personal
investment transactions made by Terry Hungle and does not
relate to the business, operations or financials of Nortel
Networks."
2/11. Michael Kinsley resigned as editor of Slate magazine.
1/31. Jano Cabrera left the Recording Industry Association of
America (RIAA) to join former Vice President Al Gore's
political action committee as communications director. Before
going to work for the RIAA he worked for the Gore Lieberman
campaign as Gore's Deputy National Spokesman. Before that he
was a Deputy Press Secretary in the Office of the Vice
President. |
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More News |
2/11. Qwest Communications
issued a release
in which it stated that it "has received a subpoena for
documents concerning Global
Crossing Ltd. from the Securities
and Exchange Commission (SEC) in connection with the SEC's
investigation of Global Crossing. The company intends to
cooperate fully with the SEC."
2/11. The General Accounting
Office (GAO) released a report [PDF]
titled "Tax Administration: Electronic Filing's Past and
Future Impact on Processing Costs Dependent on Several
Factors". The report found that "From fiscal years
1997 through 2000, the number of individual and business tax
returns filed electronically increased from almost 23 million
to almost 41 million." However, over the same time
period, the total amount spent by the IRS processing all
returns -- both paper and electronic -- still increased 16%.
The report was prepared at the request of Rep. Amo Houghton
(R-NY), the Chairman of the House Ways and Means
Committee's Subcommittee on Oversight. |
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7th Circuit Rules on
Ownership of Software |
2/11. The U.S.
Court of Appeals (7thCir) issued its opinion
in Dispatch
Automation v. Richards, a contract dispute
involving ownership of a software program. The Appeals Court
addressed what constitutes a development of an existing
program, and what constitutes a new product. The Appeals Court
also commented on the economics of software ownership.
Background. Anthony Richards is a software developer
who wrote a computer program called RIMS to help police and
fire departments with records management and vehicle dispatch.
He copyrighted the program. Richards and his wife formed a
corporation named Dispatch Automation, Inc., with Gary Hagar
and his wife for the purpose of licensing the software to
police and fire departments. Each couple took a 50% interest.
The articles of incorporation provided further that Richards
retained ownership of the program, and that Richards agreed to
license it to Dispatch Automation for $1 per year. It also
stated that the corporation may continue to develop the
product, but all ownership rights remain with Richards. The
two couples had a falling out, Richards resigned from the
company, and cancelled Dispatch Automation's license to market
the program.
District Court. Dispatch Automation filed a complaint
in U.S. District Court
(WDWisc) against Richards alleging breach of contract.
Federal jurisdiction in this case is based upon diversity of
citizenship. Wisconsin law applies. The parties agreed that
Richards owned products that were "developments" of
the products that he had licensed to the corporation when it
was formed, but not new products. Dispatch Automation argued
that "developments" are small, incremental changes
and that the latest version of the product was so different
from the earlier versions that it was a new product. Richards
argued that a "new" product is one that is not
encompassed by the contractual term "RIMS group of
computer aided dispatch and records management software
products." The District Court granted summary judgment to
Richards.
Appeals Court. The Appeals Court affirmed. Judge
Richard Posner, writing for the three judge panel, noted
that "It would have been cockeyed -- it would have been
contrary to Dispatch Automation's own interests as they then
appeared -- for the parties to have agreed that Richards would
own successive versions provided they made only incremental
improvements over their predecessors but that he would have no
rights to a successive version that made a real breakthrough.
That would have given him an incentive to pull his punches, or
to quit the company if he thought he was on the brink of a
breakthrough; neither the articles of incorporation nor, so
far as we are aware, any other contractual provision binds
Richards to Dispatch Automation. Since the corporation
received the entire income (minus $1 a year) from the sale of
programs licensed to it by Richards, it had every reason to
encourage him to make breakthroughs."
Posner then reasoned that "When a contractual
interpretation makes no economic sense, that's an admissible
and, in the limit, a compelling reason for rejecting it."
Hence, Posner, the author of Economic
Analysis of Law, and countless other works applying
economics to law, rejected Dispatch Automation's
interpretation.
Judge Posner also commented that this corporate arrangement
was unusual. He wrote that "Ordinarily an employer
insists on owning all the software developed by its employees
(unless created wholly on the employee's own time and at his
sole expense), whether it is derivative of pre-employment work
or completely new, precisely to avoid the kind of dispute that
has arisen here. For an employee to own rights to part of the
employer's output is bound to create difficult and contentious
issues of managing and tracking who owns what, and there is
also a danger that the employee will quit and take his
technology with him. Then too software development is a risky
undertaking and the employer is likely to be the superior risk
bearer, and ownership of the software shifts the risk, both
upside and downside, from the developer to the firm." |
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9th Circuit Reverses in
Trademark Case |
2/11. The U.S.
Court of Appeals (9thCir) issued its opinion
in Entrepreneur
Media v. Smith, a trademark and unfair
competition case involving the use of the trademark
"Entrepreneur" on the cover of a print publication,
in a domain name, and in other contexts. The Appeals Court
largely reversed the District Court's summary judgment for the
trademark holder, and remanded for trial.
Background. Entrepreneur Media, Inc. (EMI) publishes
magazines, books, computer software, and audio and video. It
publishes a magazine for small businesses named
"Entrepreneur". It has registered the mark
"Entrepreneur" with the USPTO. It has also
registered the domain www.entrepreneur.com.
Scott Smith has a public relations business. He did business
as EntrepreneurPR, and produced a publication by titled
"Entrepreneur Illustrated". He also registered the
domain www.entrepreneurpr.com.
District Court. EMI filed a complaint in U.S. District Court (CDCal)
against Smith alleging trademark infringement, unfair
competition, and counterfeiting under the Lanham Act, 15
U.S.C. § 1125, and unfair competition under the
California Business and Professions Code § 17200. The
District Court granted summary judgment to EMI on the
trademark infringement and unfair competition claims, awarded
damages, and enjoined Smith from using any marks confusingly
similar to "Entrepreneur".
Appeals Court. The Appeals Court affirmed in part and
reversed in part. It applied the eight factor test announced
in AMF,
Inc. v. Sleekcraft Boats, 599 F.2d 341 (9th Cir. 1979).
That is, it considered "1. The strength of EMI's
trademark; 2. The similarity of the marks; 3. The proximity or
relatedness of the goods or services; 4. Smith's intent in
selecting the marks; 5. Evidence of actual confusion; 6. The
marketing channels used; 7. The likelihood of expansion of
product lines; and, 8. The degree of care consumers are likely
to exercise."
On the first factor, the Appeals Court held that
"Entrepreneur" is a weak mark, and thus deserving
less protection, because it is a common and necessarily used
word.
On the second factor, regarding the domain name, the Court
wrote that entrepreneurpr.com is different from
entrepreneur.com, and that consumers attempting to reach the
EMI web site are unlikely to enter the former by a
typographical error. It concluded that a "juror could
reasonably find Smith's entrepreneurpr.com domain name
dissimilar from EMI's ENTREPRENEUR mark."
After weighing all eight factors, the Appeals Court concluded
that "the way Smith has used the mark "Entrepreneur
Illustrated" on the covers of EntrepreneurPR's printed
publication, as it appears in the record, would likely confuse
an appreciable number of reasonably prudent consumers, and
thus infringed EMI's trademark "ENTREPRENEUR.""
However, "As to all other allegations of trademark
infringement, EMI has not demonstrated on this record that
Smith has infringed its trademark as a matter of law. A trier
of fact could reasonably conclude that none of the eight
Sleekcraft factors weighs strongly in favor of a finding of
likely confusion as to these allegations." The Appeals
Court also reversed the summary judgment as to the unfair
competition claim. |
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Privacy Advocates Oppose
Standardization of State Driver Licensing |
2/11. A collection of groups sent a letter
to President Bush to "urge the Administration to oppose
the attempts of state motor vehicle officials to create a
national identification system (national ID) through the
bureaucratic back door of state drivers' licenses."
The signatories to the letter include the American Civil
Liberties Union (ACLU), Center
for Democracy and Technology (CDT), Electronic Privacy Information
Center (EPIC), Free
Congress Foundation (FCF), Privacilla.org, and
other groups.
The letter continues that "Once government databases are
integrated through a uniform ID, access to and uses of
sensitive personal information would inevitably expand. Law
enforcement, tax collectors, and other government agencies
would want use of the data. Employers, landlords, insurers,
credit agencies, mortgage brokers, direct mailers, private
investigators, civil litigants, and a long list of other
private parties would also begin using the ID and even the
database, further eroding the privacy that Americans rightly
expect in their personal lives. It would take us even further
toward a surveillance society that would significantly
diminish the freedom and privacy ..."
On February 7, the Progressive
Policy Institute (PPI), a Democratic think tank, released
a report
[PDF] titled "Modernizing the State Identification
System: An Action Agenda". It concludes that "our
identification system is broken" and that Congress should
require states to modernize, through such technologies as
smart ID cards.
While the PPI report opposes a national ID card, it proposes
"Modernizing the current system, in which the primary
form of identification is issued by the Department of Motor
Vehicles in each state". Specifically, the PPI report
recommends that Congress "require states to issue ``smart
ID cards´´ containing a standardized hologram and digitally
encoded biometric data specific to each holder; set standards
for initial identity verification; accelerate the linking of
state DMV databases; provide grants and loans for additional
state smart card applications; upgrade the system for foreign
visitors to incorporate a similar ``smart visa´´ program;
and create strict controls to protect privacy and prevent
abuses." See also, PPI
release.
Rep. James Moran
(D-VA) will likely soon introduce legislation that
incorporates some of the recommendations contained in the PPI
report. |
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Immersion Sues Sony and
Microsoft |
2/11. Immersion
Corporation filed a complaint in U.S. District Court
(NDCal) against Microsoft and Sony alleging patent
infringement. Immersion alleges that Microsoft's Xbox and the
Sony's PlayStation use its haptic technology. See, Immersion
release. This is case number 02-00710 CW, filed in the
Oakland Division. CW references Judge Claudia Wilken. |
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Tuesday, Feb 12 |
The House will meet at 12:30 PM for morning hour and 2:00 PM
for legislative business. The House will consider a number of
bills under suspension of the rules. At 5:30 PM the House will
consider HRes
344, a rule for consideration of HR
2356, the campaign finance bill.
9:30 AM. The U.S.
Court of Appeals (DCCir) will hear oral argument in WorldCom
v. FCC, No. 01-1218. Judges Tatel, Garland and Williams
will preside.
9:30 AM. The Senate
Governmental Affairs Committee's Subcommittee on
International Security, Proliferation and Federal Services
will hold a hearing to examine multilateral non-proliferation
regimes, weapons of mass destruction technologies, and the war
on terrorism. Location: Room 342, Dirksen Building.
10:00 AM. The Senate
Banking Committee will hold a hearing on accounting and
investor protection issues surrounding the problems with Enron
and other public companies. The witnesses will be five former
Chairmen of the Securities and
Exchange Commission (SEC), Roderick Hills (1975-77),
Harold Williams (1977-81), David Ruder (1987-89), Richard
Breeden (1989-93), and Arthur Levitt (1993-2000). Location:
Room 538, Dirksen Building.
11:00 AM. The Federal Trade
Commission (FTC) will announce a "three point program
to crack down on deceptive spam." FTC Chairman Timothy
Muris will speak. See, FTC release.
Location: FTC Internet Lab, Room 279, 600 Pennsylvania Ave.,
NW.
12:15 PM. The Federal
Communications Bar Association's (FCBA) Common Carrier
Committee will host a brown bag lunch. Kathleen
Abernathy (FCC Commissioner) and Nanette
Thompson (Chair of the Regulatory Commission of
Alaska) will speak about universal service. RSVP to
Rhe Brighthaupt at rbrighth
@wrf.com. Location: Wiley
Rein & Fielding, 1750 K St., NW, 10th Floor.
12:15 PM. The Federal
Communications Bar Association's (FCBA) Transactional
Practice Brown Committee will host a brown bag lunch on
wireless transactions. RSVP to Tina Screven at 202 383-3337.
Location: Wilkinson Barker
& Knauer, 2300 N Street NW.
12:30 PM. Salvatore Sodano, Ch/CEO of the American Stock
Exchange will give a speech titled "Challenges Facing the
Capital Markets as a Result of September 11th and Enron".
Location: Ballroom, National
Press Club, 529 14th St. NW, 13th Floor.
2:30 PM. The Senate
Foreign Relations Committee will hold a hearing to examine
the theft of American intellectual property at home and
abroad. The scheduled witnesses include Alan Larson (Under
Secretary of State), Peter Allgeier (Deputy U.S. Trade
Representative), John Gordon (U.S. Attorney, Central District
of California), Jack Valenti (P/CEO of the Motion Picture
Association of America), Hilary Rosen (P/CEO of the Recording
Industry Association of America), and Jeff Raikes (Microsoft).
Location: Room 419, Dirksen Building.
4:00 PM. The House
Judiciary Committee's Crime Subcommittee will hold a
hearing on HR
3482, the "Cyber Security Enhancement Act of
2001", sponsored by Rep. Lamar Smith
(R-TX). Location: Room 2237, Rayburn Building.
7:15 PM. FTC Chairman Timothy Muris will speak at the American
Bar Association Antitrust Section Corporate Counsel Dinner.
Location: Willard Intercontinental Hotel, 1401 Pennsylvania
Ave., NW. |
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Wednesday, Feb 13 |
The House will likely begin its consideration of HR
2356, the campaign finance bill.
Day one of a three day conference titled Biometric
Consortium Conference. The sponsors include the
Information Technology Laboratory (ITL) and the Advanced
Technology Program (ATP) of the National Institute of
Standards and Technology (NIST), the National Security Agency
(NSA), the Department of Defense's Biometric Management Office
(BMO), the General Services Administration (GSA), and the
Federal Technology Service (FTS) Center for Smart Card
Solutions. This conference has been rescheduled from September
12-14, 2001. See, conference
web site. Location: Hyatt Regency Crystal City, Arlington,
VA.
10:00 AM - 12:00 NOON. The House Science Committee
will hold a hearing titled "R&D Budget for Fiscal
Year 2003: An Evaluation". The witnesses will be Jack
Marburger (Director, Office of Science and Technology Policy),
Rita Colwell (Director, National Science Foundation), Samuel
Bodman (Deputy Secretary, Department of Commerce), Bruce
Carnes (Department of Energy). Location: Room 2318, Rayburn
Building.
11:00 AM. The Cato Institute
will host a panel discussion titled "Trade War or Tax
Reform? The WTO Ruling on Tax Breaks for U.S. Exporters".
The panelists will be Rep.
Phil Crane (R-IL), Chairman of the Trade Subcommittee of
the House Ways and
Means Committee, William Reinsch, National
Foreign Trade Council, John Meagher, Price Waterhouse Coopers,
and Chris Edwards, Cato Institute. Cato will web cast the
event. A luncheon will follow the program. See, Cato event
summary. Location: Cato Institute, 1000 Massachusetts
Avenue, NW.
2:00 PM. The Senate
Judiciary Committee's Administrative Oversight and the
Courts Subcommittee will hold a hearing titled
"Administrative Oversight: Are We Ready For A Cyber
Terror Attack?". Sen.
Charles Schumer (D-NY) will preside. Location: Room 226,
Dirksen Building.
5:00 - 7:00 PM. The Congressional
Internet Caucus Advisory Committee will host an event
titled "Reception and Technology Fair". Each of the
Co-chairs of the Internet Caucus, Sen. Patrick Leahy (D-VT),
Sen. Conrad Burns
(R-MT), Rep. Bob
Goodlatte (R-VA) and Rep. Rick Boucher
(D-VA), is likely to speak. The Co-chairs of the Wireless Task
Force, Sen. John Ensign
(R-NV) and Rep. Mike
Honda (D-CA), are likely to speak also. Location: Room
902, Hart Building. |
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Thursday, Feb 14 |
The House will likely continue its consideration of HR
2356, the campaign finance bill.
Day two of a three day conference titled Biometric
Consortium Conference. See, conference
web site. Location: Hyatt Regency Crystal City, Arlington,
VA.
The Forum on Technology and Innovation (Tech Forum) will hold
a event relating to cyber security. The speakers will
be Richard Clarke (Special Advisor to the President for
Cyberspace Security), Vint Cerf (WorldCom), and Bruce
Schneier (CTO of Counterpane
Internet Security). The Tech Forum was founded by Sen. Bill Frist (R-TN), Sen. Jay Rockefeller
(D-WV), and the Council on
Competitiveness.
9:30 AM. The Federal
Communications Commission (FCC) will hold a meeting. See, FCC
release. Location: Room TW-C305, 445 12th St., SW.
9:30 AM. The House
Commerce Committee's Subcommittee on Commerce, Trade, and
Consumer Protection will hold a hearing titled "Are
Current Financial Accounting Standards Protecting
Investors?" Location: Room 2212, Rayburn Building.
10:00 AM. The House
Judiciary Committee's Subcommittee on Courts, Internet and
Intellectual Property will hold a hearing on the "Federal
Trademark Dilution Act." Location: Room 2141, Rayburn
Building.
2:30 PM. The Senate
Judiciary Committee's Technology, Terrorism, and
Government Information Subcommittee will hold a hearing on privacy,
identity theft, and protection of personal information. Sen. Dianne Feinstein
(D-CA) will preside. Location: Room 226, Dirksen Building. |
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Friday, Feb 15 |
The House will not be in session.
Day three of a three day conference titled Biometric
Consortium Conference. See, conference
web site. Location: Hyatt Regency Crystal City, Arlington,
VA.
8:00 AM - 2:00 PM. The National
Science Foundation's (NSF's) Advisory Committee for
Cyberinfrastructure will hold an open meeting. See, notice
in Federal Register. Location: Room 1150, NSF, 4201 Wilson
Blvd., Arlington, VA.
9:30 AM. The U.S.
Court of Appeals (DCCir) will hear oral argument in New
World Radio v. FCC, No. 1110. Judges Henderson, Randolph
and Rogers will preside.
12:00 NOON. Deadline to submit comments to the Office of the U.S. Trade Representative
(USTR) regarding foreign countries that deny adequate and
effective protection of intellectual property rights or deny
fair and equitable market access to U.S. persons who rely on
intellectual property protection. The USTR requests comments
pursuant to its duties under § 182 of the Trade Act of
1974, 19
U.S.C. § 2242, which is better known as the "Special
301" provisions. See, notice
in the Federal Register.
Extended deadline to file reply comments with the FCC in its
proceeding regarding cross ownership of broadcast stations
and newspapers. This is MM Docket No. 01-235. See, notice
in Federal Register. |
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