Lucent May Be Liable in
Contract for Delay in Filing SEC Form S-3 |
9/3. The U.S.
Court of Appeals (5thCir) issued its opinion
[21 pages in PDF] in Herrmann
Holdings v. Lucent, holding, as matter of Texas
law, that a clause in a merger contract that provides that the
acquiring company will use its best efforts to promptly file
an S-3 form with the SEC, may give rise to a breach of
contract action.
Background. Herrmann Technology, Inc. (HTI) designed
and developed passive thin film filters for use in
telecommunications optical networking. It was owned by
Herrmann Holdings Ltd and others (hereinafter Herrmanns). On
June 16, 2000, Lucent and the Herrmanns signed an agreement
whereby Lucent acquired
HTI for 6,770,200 shares of Lucent stock, then worth about
$438 Million, based on the closing stock price of $60.
The Herrmanns could not sell any of their Lucent stock in a
public transaction on the open market until Lucent filed, and
the Securities and Exchange
Commission (SEC) declared effective, a Form S-3
registration statement. Under the agreement, Lucent was to
"use its reasonable best efforts to prepare, file and
cause to become effective, as promptly as practicable".
However, Lucent repeatedly delayed, over the Herrmanns'
objections. It took six weeks to file. During this delay, the
price of Lucent stock dropped by nearly one third.
District Court. The Herrmanns filed a complaint in U.S. District Court (NDTex)
against Lucent. Jurisdiction was based upon diversity of
citizenship. The Herrmanns alleged breach of contract and
violations of Article 581-33 of the Texas Securities Act and
Section 27.01 of the Texas Business and Commerce Code. The
District Court dismissed the complaint for failure to state a
claim, pursuant to FRCP 12(b)(6), and failure to plead fraud
with specificity, pursuant to FRCP 9(b), and entered judgment
for Lucent. The Herrmanns appealed.
Appeals Court. The Appeals Court reversed the dismissal
as to the contract claim, but affirmed as to the two other
claims.
The Court first addressed the breach of contract claim. It
noted that as a diversity case, it would apply the law of the
state, Texas. However, it concluded that "The Texas
Supreme Court has not yet ruled on the enforceability of best
efforts clauses in breach of contract actions." Hence, it
predicted how the Texas Supreme Court would rule on this
issue, pursuant to Erie v. Tompkins.
The Appeals Court concluded that "the goal or guideline
established by the best efforts provision in the Agreement was
for Lucent to file and cause to become effective, ``as
promptly as practicable´´ and ``in the most expeditious
manner practicable,´´ a registration statement covering the
Herrmanns' shares. Here, by alleging that the parties had a
contract, that it contained two ``best efforts´´ provisions
that required Lucent to file and cause the S-3 to become
effective ``as promptly as practicable´´ and ``in the most
expeditious manner practicable,´´ that Lucent breached that
contractual obligation, and that the Herrmanns suffered
damages as a result of that breach, the Herrmanns successfully
state a claim for breach of contract. ... Therefore, the
district court erred in dismissing the Herrmanns' breach of
contract claim."
The Appeals Court affirmed the Districts Court's dismissal of
the two other claims. It affirmed the dismissal of the Texas
securities fraud claim, for failure to plead fraudulent intent
adequately under Rule 9(b); however, it allowed the Herrmanns
leave to amend this claim. |
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WTO Issues FSC/ETI
Countermeasures Decision |
8/30. The World Trade
Organization (WTO) issued a Decision
of the Arbitrator [46 pages in PDF] in the FSC/ETI matter.
The WTO had previously held that the United States' Foreign
Sales Corporation (FSC) tax regime, and its replacement, the
Extraterritorial Income (ETI) regime, constitute illegal
export subsidies. This decision authorizes the EU to impose $4
Billion in counter measures.
It the EU were to impose counter measures, they might target,
among other things, exports by U.S. technology companies.
U.S. Trade Representative (USTR)
Robert
Zoellick stated in a release
that "I'm disappointed that the arbitrator did not accept
the lower figure put forward by the United States. We believe
that $1 billion is much more accurate, ... Nevertheless, the
key point, as the President has said, is that the Executive
branch will work with Congress to fully comply with our WTO
obligations. I believe that today's findings will ultimately
be rendered moot by U.S. compliance with the WTO's
recommendations and rulings in this dispute."
Similarly, Deputy Secretary of the Treasury Ken Dam stated in
an August 30 release
that "As the President has stated, the United States will
comply with the WTO decision in this case. Therefore, I am
confident that today's findings regarding damages will be
rendered moot by our coming into compliance. We look forward
to working with the Congress to enact changes to our tax law
that will preserve the competitiveness of U.S. businesses and
American workers while honoring our WTO obligations."
Rep. Bill Thomas
(R-CA), the Chairman of the House Ways and Means
Committee, introduced HR 5095,
the American Competitiveness and Corporate Accountability Act
of 2002, on July 11, 2002, to address the WTO's rulings
regarding the FSC and ETI. See also, Rep. Thomas' summary.
However, no action has been taken on the bill. Also, there is
no replacement legislation pending in the Senate.
EU Trade Commissioner Pascal
Lamy said in a release
that "We need to see compliance in a series of steps.
President Bush took a first important step at the last EU-US
Summit by stating that the US Administration will do
everything in its power to comply. Another important step has
been accomplished with the introduction of the Thomas bill in
Congress that is manifestly intended to bring the US into
compliance. We call on the US Congress to act quickly so that
legislation will move forward and enable repeal of the FSC/ETI
scheme within a short period of time."
Lamy concluded that "The path is now clear for the EU to
adopt sanctions if the US does not repeal the FSC/ETI scheme
expeditiously. We will consult with our industry and the
Member States on a detailed product list of possible
countermeasures to be notified to the WTO. Before any
countermeasures are taken, we will carefully evaluate progress
made on US implementation."
Mike Moore, who just stepped down as Director General of the
WTO, stated in a release
that "The arbitration ruling marks a further stage of WTO
involvement in this long running and difficult dispute. I have
been following the FSC case closely and I commend both parties
for working in a constructive manner throughout the duration
of this dispute. I urge both parties to continue to cooperate
and work toward resolving this dispute and the others between
them in an amicable and constructive fashion. The European
Union and the United States are among the most important
members of this organization and both hold a special
responsibility to ensure the continued health and soundness of
WTO and global trading system." |
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New WTO Director To Pursue
Doha Agenda |
9/2. The new World Trade
Organization (WTO) Director General, Supachai Panitchpakdi,
held his first press conference. He began by stating that
"One of the most urgent issues that I intend to undertake
is to see to it that we move into the phase of substantive
negotiation under the Doha Development Agenda as soon as we
can, as intensively as we can, as productively as we
can." See, transcript. |
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GAO Reports on Technology
Issues in Homeland Defense |
8/30. The General Accounting
Office (GAO) released a letter [7
pages in PDF] to Rep.
Tom Davis (R-VA) in which it responds to his questions
regarding "National Preparedness: Technology and
Information Sharing Challenges".
The letter addresses agency turf battles, antitrust and FOIA
obstacles to information sharing, the use of shared databases,
research and development, information sharing by government
agencies, the use of Extensible Markup Language (XML), and the
use of customer relationship management (CRM) techniques and
technology for homeland defense. |
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California Governor Signs
Community Technology Programs Bill |
8/28. California Gov. Gray Davis signed SB
1863, sponsored by Sen. Debra
Bowen (D - Marina del Rey). It would require the California Public Utilities
Commission to provide a nonprofit community technology
program with discounts comparable to those that are provided
to schools and libraries to address inequality of access to
advanced telecommunications services.
This bill amends the California Public Utilities Code to
provide that "It is the intent of the Legislature that
any program administered by the commission that addresses the
inequality of access to advanced telecommunications services
by providing those services to schools and libraries at a
discounted price should also provide comparable discounts to a
nonprofit community technology program." |
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People and Appointments |
9/3. President Bush nominated Scott Muller to be
General Counsel of the Central Intelligence Agency (CIA). See,
White
House release. |
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Verizon and Privacy Groups
Oppose RIAA Subpoena |
8/30. Verizon and a collection of privacy groups have filed
briefs with the U.S.
District Court (DC) in a proceeding brought by the RIAA
for the purpose enforcing a subpoena of Verizon's Internet
services subsidiary. The RIAA motion states that it seeks the
identity of the user of "a computer connected to the
Verizon network that is a hub for significant music
piracy". Verizon argues that the asserted basis for the
subpoena, the DMCA, does not extend to situations such as
this, where the alleged infringing material is stored on the
computer of Verizon's customer, as opposed to Verizon's own
system, and Verizon only serves an a communications conduit
for the customer.
On August 20, the Recording
Industry Association of America (RIAA) filed its motion
and memorandum [19 pages in PDF] in U.S. District Court (DC)
in a proceeding brought by the RIAA for the purpose of
enforcing a subpoena of Verizon's Internet services
subsidiary. The RIAA motion states that it seeks to enforce a
subpoena issued on July 24, 2002, pursuant to the Digital
Millenium Copyright Act (DMCA). It states that "Verizon
has refused to comply."
17
U.S.C. § 512(h) provides, in part, that "A copyright
owner or a person authorized to act on the owner's behalf may
request the clerk of any United States district court to issue
a subpoena to a service provider for identification of an
alleged infringer in accordance with this subsection."
Subsection 512(h)(5) provides, in part, that "Upon
receipt of the issued subpoena, ... the service provider shall
expeditiously disclose to the copyright owner or person
authorized by the copyright owner the information required by
the subpoena, notwithstanding any other provision of law and
regardless of whether the service provider responds to the
notification."
Verizon argues that the
subpoena is invalid and should not be enforced, because
Section 512 applies only when the infringing material is
stored on the equipment of the subpoenaed party, and because
there is no case or controversy within the meaning of Article
III of the Constitution.
Verizon states that "It is clear from RIAA's assertion,
however, that Verizon did not store any of the challenged
sound files on its system or network. Verizon thus was not
involved with the subscriber's activities except, at most, as
a passive conduit within the meaning of subsection
512(a)."
Verizon then argues that "The subpoena power set forth in
subsection 512(h) of the DMCA does not apply when the service
provider acts as a passive conduit. The statute strictly
confines the subpoena power to circumstances where the
assertedly infringing material is stored on the service
provider's system or network."
Verizon continues that "RIAA is seeking to expand the
subsection 512(h) subpoena power to reach all Internet users,
not just those who store infringing material on a service
provider's system or network. RIAA proposes a dazzlingly broad
subpoena power that would allow any person, without filing a
complaint, to invoke the coercive power of a federal court to
force disclosure of the identity of any user of the Internet,
based on a mere assertion in a form submitted to the court's
clerk that the user is engaged in infringing activity."
Verizon further argues that "Such a broad ranging
invocation of federal judicial authority, as a pure
investigative tool outside of the context of a pending case,
raises substantial questions as to whether it exceeds the
power of an Article III court."
Verizon further argues that "Permitting forced disclosure
of the identities of Internet users, without a ``case or
controversy´´ in the form of a filed lawsuit, would pose a
grave threat of widespread abuse of this Court's subpoena
power based on flimsy assertions of copyright infringement --
including by marketers, pormographers, and others who could
invoke the DMCA procedures under the unfettered subpoena
authority posited by RIAA." (Word misspelled by TLJ to
evade email blocking.)
Verizon also raises a First Amendment argument, which the
amicus brief addresses in more detail.
On August 30 a collection of privacy groups, including the Electronic Privacy Information
Center (EPIC), filed an amicus curiae brief that
emphasizes the First Amendment right of anonymous speech.
The amici argue that "Not only was the statute never
intended to reach a situation in which the allegedly
infringing material resides on the user’s own computer
rather than a computer owned or controlled by the ISP, but the
application of the statute as RIAA urges highlights the
constitutional infirmities of Section 512(h) itself. The
statute provides that, upon an unsupported allegation of
copyright infringement by an Internet user on his own
computer, a clerk of a court, without any substantive review
by the court itself, must issue a subpoena to the user's ISP
for the identity of the user. Yet, under the Constitution,
anonymous speech is protected. Thus, this case falls into the
line of cases that have established safeguards for protecting
the anonymity of Internet speakers who have not been shown to
have engaged in any prohibited conduct."
The amici argue that the relevant subpoena provision of the
statute is unconstitutional, or in the alternative, that the
Court should infer procedural due process provisions,
including "notice, an opportunity to object, and judicial
review".
Verizon's brief was written William
Iverson and others at the law firm of Covington and Burling. The
amicus brief was written by Megan Gray and others.
The proceeding is titled "In Re Verizon Internet
Services, Inc.; Recording Industry Association of America v.
Verizon Internet Services, Inc." It is D.C. No.
1:02MS00323. The RIAA's reply brief is due on Wednesday,
September 4. |
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EPIC and Privacy
International Release Annual Privacy Report |
9/3. The Electronic Privacy
Information Center (EPIC) and Privacy
International released the 2002 edition of their annual
survey of the state of privacy in over fifty countries. It is
titled "Privacy and Human Rights 2002: An International
Survey of Privacy Laws and Developments".
The report can be downloaded in three parts, without charge.
See, Analysis:
Forward, Overview, Threats to Workplace Privacy [111 pages
/ 782KB in PDF], Country
Reports: Argentina to Lithuania [985 KB in PDF], and Country
Reports: Luxenbourg to United States [855 KB in PDF].
Alternatively, the report can be purchased in hard copy from
EPIC's online
bookstore. See also, Privacy
International release.
The report concludes that "The events of September 11,
2001 brought new challenges to the protection of privacy in
the modern era. In the rush to strengthen national security
and to reduce the risk of future terrorist acts, governments
around the world turned to legal authority and new technology
to extend control over individuals. Many of these proposals
have had far-reaching consequences for the protection of
privacy."
"Another significant development was the adoption, in
June 2002, of the European Union's Electronic Communications
Privacy Directive. This Directive allows European Union member
states to enact laws requiring Internet Service Providers, and
other telecommunications operators, to retain the traffic and
location data of all people using mobile phones, text
messaging, land-line telephones, faxes, e-mails, chatrooms,
the Internet, or any other electronic communication devices,
to communicate."
However, the report also finds that "efforts to pass new
data protection laws or to strengthen existing laws are
continuing in Eastern Europe, Asia and Latin America." In
addition, "laws or codes to protect privacy in the
workplace are gaining more prominence." |
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INTA Files Amicus Brief in
Trademark Dilution Case |
8/26. The International
Trademark Association (INTA) filed an amicus
curiae brief [39 pages in PDF] with the Supreme Court in Moseley
v. V. Secret Catalogue, a trademark case. At
issue is whether the plaintiff in a lawsuit for violation of
the Federal Trademark Dilution Act (FTDA) must show actual
economic loss.
Background. Victoria's
Secret filed a complaint in U.S.
District Court (WDKent) against Victor Moseley alleging
trademark infringement and violation of the FTDA, 15
U.S.C. § 1125(c), in connection with his use of the
name "Victor's Little Secret" for a lingerie and
adult toy business. The District Court granted summary
judgment to Moseley on the federal trademark infringement
claims, finding that Victoria's Secret had not provided
sufficient evidence to establish a likelihood of confusion
between the two marks. The District Court also found that the
Victor's Little Secret mark both blurred and tarnished the
Victoria's Secret mark under the FTDA and enjoined Moseley
from making further use of the Victor's Little Secret mark.
Moseley appealed the District Court's FTDA ruling. The U.S. Court of Appeals
(6thCir) issued its opinion
on July 30, 2001, affirming the District Court. It held that
economic harm may be inferred in trademark dilution claims.
The Supreme Court granted certiorari on April 15, 2002.
The Supreme Court's review will resolve the differences
between various circuits on this issue. See, for example, Nabisco
v. PF Brands, 191 F.3d 208 (2d Cir. 1999) and Ringling
Bros. Barnum & Bailey v. Utah, 170 F.3d 449 (4th Cir.
1999).
INTA Brief. The INTA supports the interpretation
contained in the Sixth Circuit opinion under review, and
opposes that of the Fourth Circuit (which requires actual
harm).
The INTA wrote that "Section 43(c) of the Lanham Act, 15
U.S.C. § 1125(c) (2000), provides that the ``[t]he owner of a
famous mark shall be entitled … to an injunction against
another person’s commercial use of a mark … [that] causes
dilution of the distinctive quality of the famous mark.´´
The Court of Appeals for the Fourth Circuit reads the section
to require ``actual harm to … economic value´´: i.e.,
"an actual lessening of the [famous] mark's selling
power, expressed as ‘its capacity to identify and
distinguish goods or services.’´´" (Citing Ringling
Bros. v. Utah.)
However, INTA argues that "section 43(c) does not refer
to ``actual harm´´ or to an ``actual lessening´´ of
selling power -- and none of the principles of statutory
construction that petitioners espouse mandate adding those
words to give plain meaning to the law."
See also, INTA
release. |
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Wednesday, September 4 |
The House will return from its Summer District Work Period.
It will meet at 2:00 PM for legislative business. No votes are
expected before 6:30 PM. The House will consider a number of
non tech related measures under suspension of the rules. See, Whip
Notice.
Deadline to submit comments to the National Intellectual
Property Law Enforcement Coordination Council (NIPLECC)
regarding its agenda and mission. The NIPLECC is co-chaired by
the U.S. Patent and Trademark
Office (USPTO) and the Department of Justice (DOJ). See, notice
in Federal Register. See also, the NIPLECC's 2000
report.
Day one of a three day meeting titled "U.S. Ireland
Business Summit". The only event on September 4 is an
evening reception on Capitol Hill in the Cannon Caucus Room
from 6:30 - 8:30 PM. See, conference web site.
Deadline for the Recording
Industry Association of America (RIAA) to file its reply
brief with the U.S.
District Court (DC) in RIAA v. Verizon, an action
to enforce a subpoena pursuant to the Digital Millenium
Copyright Act (DMCA), at 17
U.S.C. § 512(h). This is D.C. No. 1:02MS00323. |
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Thursday, September 5 |
The House will meet at 10:00 AM for legislative business. It
will consider several non tech related bills. See, Whip
Notice.
8:30 AM - 6:00 PM. Day one of a two day conference titled
"Symposium on the Role of Scientific and Technical
Data and Information in the Public Domain" hosted by
the National Academy of Sciences.
See, agenda.
Location: National Academy of Sciences Auditorium, 2100 C
Street NW.
9:30 AM. The U.S.
Court of Appeals (DCCir) will hear oral argument in CompTel
v. FCC, No. 00-1272. This is a petition for review of the FCC's June 2000 Supplemental
Order Clarification of the FCC's Local Competition Order. CompTel challenges the
FCC's authority to restrict access to unbundled network
elements (UNEs), and especially enhanced extended links
(EELs). See, brief
[PDF] of CompTel.Judges Edwards, Rogers and Williams will
preside. Location: Courtroom 20, 333 Constitution Ave., NW.
10:00 AM. The House
Judiciary Committee will hold a meeting to mark up several
bills. The last item on the agenda is HR
4561, the Federal Agency Protection of Privacy Act,
sponsored by Rep. Bob
Barr (R-GA). The bill would require federal agencies to
the agency shall prepare and make available for public comment
an initial privacy impact analysis when it proposes new
regulations. Location: Room 2141, Rayburn Building.
10:00 AM. The Senate
Judiciary Committee will hold an executive business
meeting. See, notice.
Location: Room 226, Dirksen Building.
12:00 NOON. William Lash (Assistant Secretary of Commerce for
Market Access and Compliance) will speak on "Trade
Compliance After TPA". Location: Heritage Foundation, 214
Massachusetts Ave NE.
2:00 - 4:00 PM. The Federal
Communications Commission's (FCC) Advisory Committee for
the 2003 World Radiocommunication Conference (WRC-03 Advisory
Committee) will hold a meeting. This meeting was originally
scheduled for August 22. See, original notice
in Federal Register, and rescheduling notice
in Federal Register. Location: Commission Meeting Room
(TW-C305), 445 12th Street, SW.
Day two of a three day meeting titled "U.S. Ireland
Business Summit". Secretary of Commerce Don
Evans is scheduled to speak at 9:30 AM. From 2:30 - 4:30
PM there will be a panel discussion titled "Information
and Communications Technology". The scheduled
panelists include FCC Commissioner Kevin Martin.
See, conference web
site. Location: Ronald Reagan Building.
Deadline to request to testify before the Trade Policy Staff
Committee (TPSC) hearing on China's compliance with the
commitments it made in connection with its accession to the World Trade Organization (WTO).
See, U.S. Trade Representative
(USTR) notice
in the Federal Register. |
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Friday, September 6 |
The House and Senate will hold a joint meeting in New York
City.
9:30 AM. The U.S.
Court of Appeals (DCCir) will hear oral argument in Motion
Picture Association of America v. FCC, No. 01-1149. Judges
Edwards, Henderson and Rogers will preside. Location: 333
Constitution Ave., NW.
8:30 AM - 4:00 PM. Day two of a two day conference titled
"Symposium on the Role of Scientific and Technical
Data and Information in the Public Domain" hosted by
the National Academy of Sciences.
See, agenda.
Location: National Academy of Sciences Auditorium, 2100 C
Street NW.
Day three of a three day meeting titled "U.S. Ireland
Business Summit". See, conference web site.
Location: Ronald Reagan Building. |
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Monday, September 9 |
9:30 AM. The U.S.
Court of Appeals (DCCir) will hear oral argument in WorldCom
v. FCC, No. 01-1198. Judges Tatel, Garland and Williams
will preside. Location: Courtroom 20, 333 Constitution Ave.,
NW.
Day one of a two day conference on patent interference law,
hosted by the Intellectual
Property Owners Association (IPO). For more information,
call 202 466-2396. Location: Ronald Reagan International Trade
Center. |
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Tuesday, September 10 |
9:30 AM. The U.S.
Court of Appeals (DCCir) will hear oral argument in AT&T
v. FCC, No. 01-1188. Judges Ginsburg, Sentelle and
Silberman will preside. Location: 333 Constitution Ave., NW.
12:00 NOON. The FCBA's
Engineering and Technical Practice Committee will host a brown
bag lunch titled "Spectrum Management Reform:
Preliminary Perspectives". The scheduled speakers are
Paul Kolodzy (FCC Senior Spectrum Policy Advisor) and Mike
Gallagher (NTIA).
RSVP to Lisa Gaisford.
Location: FCC, 445 12th St., SW, Courtyard Level, Conference
Rooms B418 & B511.
12:00 NOON. Deadline to submit written commits to the Office
of the USTR in response to its
notice
in the Federal Register requesting comments on China's
compliance with the commitments it made in connection with its
accession to the World Trade
Organization (WTO).
Day two of a two day conference on patent interference law,
hosted by the Intellectual
Property Owners Association (IPO). For more information,
call 202 466-2396. Location: Ronald Reagan International Trade
Center.
The Intellectual Property Owners
Association (IPO) Board of Directors will hold a meeting. |
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4th Circuit Rules on Pole
Attachments Act and Exhaustion of Administrative Remedies |
8/30. The U.S.
Court of Appeals (4thCir) issued its opinion
[12 pages in PDF] in Cavalier
Telephone v. Virginia Power, reversing a
preliminary injunction in a pole attachments case, for failure
to exhaust administrative remedies before the FCC.
Cavalier Telephone is a
facilities based competitive local exchange carrier (CLEC)
that provides telecommunications services to residential and
business customers in several parts of the state of Virginia. Virginia Power is an electric
utility that provides power to homes and businesses through a
network of approximately one million poles. Cavalier seeks
access to Virginia Power's poles.
Cavalier first filed a complaint with the Federal Communications Commission
(FCC) alleging that Virginia Power denied it access to its
poles in violation of the Pole Attachment Act, which requires
utilities such as Virginia Power to provide "any
telecommunications carrier with nondiscriminatory access to
any pole, duct, conduit, or right-of-way owned or controlled
by it." See, 47
U.S.C.A. § 224.
The FCC issued an order compelling Virginia Power to expedite
processing of permits, among other things. The FCC later
issued a second order terminating Virginia Power's annual pole
attachment rate of $37.00 per pole, substituting a rate of
$5.12, and ordering Virginia Power to compensate Cavalier for
previous overcharges. Virginia Power then filed an application
for review with the FCC.
Without waiting for the FCC's determination on Virginia
Power's application for review, Cavalier filed a complaint
with the U.S. District
Court (EDVa) against Virginia Power seeking enforcement of
the FCC order. The District Court granted Cavalier a
preliminary injunction.
The Appeals Court reversed and remanded with instructions to
dismiss the complaint. It held that the administrative process
before the FCC had not been completed. Cavalier can not seek
judicial enforcement of the Pole Attachments Act, or an FCC
order thereunder, until it has exhausted its administrative
remedies. |
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