Max Larson

Max Larson is an associate in the firm’s Washington, DC office. She is a member of the Technology and Communications Regulation Practice Group.

This quarterly update highlights key legislative, regulatory, and litigation developments in the first quarter of 2025 related to artificial intelligence (“AI”), connected and automated vehicles (“CAVs”), and cryptocurrencies and blockchain. 

I. Artificial Intelligence

I.  Federal Legislative Developments

In the first quarter, members of Congress introduced several AI bills addressing

Continue Reading U.S. Tech Legislative & Regulatory Update – First Quarter 2025

Yesterday, the Federal Communications Commission (FCC) released the agenda for its February Open Meeting, which is scheduled for February 27, 2025.  This is the first agenda released by the FCC under new Chairman Brendan Carr.  The agenda items on which the commissioners will vote at the meeting will include

Continue Reading FCC to Tackle Robust Agenda at February Open Meeting

On January 3, 2025, the Federal Trade Center (“FTC”) announced that it reached a settlement with accessiBe, a provider of AI-powered web accessibility software, to resolve allegations that the company violated Section 5 of the FTC Act concerning the marketing and stated efficacy of its software. 

The complaint alleges that

Continue Reading AI Accessibility Software Provider Settles FTC Allegations

On December 27, 2024,  the National Telecommunications and Information Administration (NTIA) issued a Request for Comment (“RFC”)that seeks public input on the potential impacts on the Global Positioning Satellite (GPS) L1 signal by the growth of satellite-based direct-to-device (D2D) operations that use frequencies between 1610-1660.5 MHz (the “L-band”).   As the lead spectrum advisor to the Executive Branch on spectrum issues, NTIA serves as the advocate for other agencies including the Department of Transportation (DOT) before the FCC.  NTIA issued its Request for Comment (RFC) in response to analysis prepared by DOT and states that its interest in D2D usage stems from the increasing deployment of services in which mobile devices like smartphones and Internet of Things (IoT) devices connect directly to satellite systems in the L-band, a portion of which is located near spectrum allocated to GPS.  NTIA invited comments to be filed by February 10, 2025. 

In its RFC, NTIA asked parties to discuss the DOT technical analysis as well as options for mitigating any potential impacts on GPS systems while “facilitating the potential benefits” of a growing D2D ecosystem.  The FCC has exclusive authority over requirements on L-band operators and their devices, but NTIA could use information gleaned from the comment process to make recommendations to the FCC on whether new spectrum rules are needed.  As such, satellite industry stakeholders, device manufacturers, and wireless network providers may want to share their views and educate NTIA about how this band is (and will be) used as well as its potential for coexistence with GPS devices. 

The DOT technical analysis included in the RFC builds on a study conducted by DOT in 2018 to analyze Ligado Network’s proposed terrestrial system.  In 2020, after receiving comments on the 2018 study, the FCC unanimously concluded that sufficient conditions – such as limited power levels and guard bands – were in place to protect against interference between GPS signals in the 1559-1610 MHz band and a terrestrial wireless network.  The technical analysis recently prepared by DOT and included in the NTIA RFC borrows heavily from the 2018 study and largely extrapolates from that study to conclude that D2D operations using the 1610-1660.5 MHz band may cause changes to the carrier-to-noise ratio (e.g., a 1 dB C/No) that could impair GPS receivers operating in the adjacent 1559-1610 MHz band.  (It bears mention that DOT for many years has urged the FCC to protect GPS devices from a 1 dB change in the carrier-to-noise ratio, but the FCC has not agreed with that recommendation and instead has applied its rules on harmful interference.  See generally In the Matter of Lightsquared Technical Working Group Report et al., 35 FCC Rcd. 3772 ¶¶ 37-59 (2020).The RFC seeks comment on this DOT analysis and encourages stakeholders to file any alternative technical analyses relevant to D2D operations in the L-band and the potential effects on the GPS L1 signal.Continue Reading NTIA Seeks Comment on Potential Effects of Satellite Direct-to-Device Operations in the L-band on GPS L1 Signal