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K.C. Halm

Broadband ISPs, wireless providers, and cable operators rely on K.C. Halm for experienced counsel on a wide range of broadband policy and competition matters involving wireless licensing and spectrum acquisition, privacy and special access (business data services) regulations, and state attorney general and PSC investigations. K.C. also advises the firm’s emerging technology clients on issues arising in the use of AI and machine learning applications under existing and emerging legal frameworks. Clients operating in the industrial IoT sectors rely upon K.C. for strategic and transactional counsel in acquiring spectrum licenses and leases to support such applications. In addition, K.C. litigates network access, interconnection, and competition issues for clients in federal and state courts and before administrative agencies.

In addition, K.C. advises clients on privacy and data/network security issues under federal and state law, with a recent focus on issues arising under the Communications Assistance for Law Enforcement Act (CALEA), the telephone and cable privacy sections of the Telecommunications Act (CPNI), and mobile privacy and location-based services.

Proud to represent America’s veterans, K.C. provides pro bono counsel to vets on disability and related claims before the Veterans Administration and the U.S. Court of Appeals for Veterans Claims.

K.C.’s clients include Comcast, Charter Communications, Cricket Communications (Leap Wireless), IPC Spectrum LLC, JAB Wireless Broadband, Mediacom Communications, Rogers Communications, Shentel, Suddenlink/Altice USA, Tampnet, and Wave Broadband.

Representative Experience

Emerging Technologies

Counseling cloud service provider on AI deployment

Advising leading cloud service provider on legal, ethical, and policy risks and issues arising from provision of services leveraging artificial intelligence applications (utilizing machine learning, deep learning, and neural networks) deployed in wholesale and retail services. (Ongoing)

Facial recognition use and deployment issues

Counseling developer of AI and machine learning applications on issues surrounding deployment and use of facial recognition and related technologies in public and semi-public locations. (Ongoing)

Spectrum acquisitions for IoT services

Representing industrial IoT service provider in transactions to secure FCC wireless spectrum licenses (700 & 220 MHz) for SCADA and other industrial IoT applications. (Ongoing)

Shared spectrum technology and licensing

Representing leading cable broadband provider, Comcast, in acquisition of experimental licenses leveraging shared spectrum technology in 3.5 GHz “CBRS” band for testing of commercial fixed and mobile wireless solutions. (Ongoing)

Wireless/Spectrum Acquisition

3.5 GHz CBRS spectrum band licensing and acces

Assisting national cable client with acquisition of experimental license to operate and test mobile and fixed wireless equipment in the 3.5 GHz CBRS band. (Ongoing)

Spectrum licensing, sharing, and transactions

Advised clients engaging in spectrum transactions, including FCC enhanced factor review for spectrum below 1 GHz, competition analysis, build-out rules, and other regulatory issues. (2016)

Spectrum licensing, sharing, and transactions for private equity firms

Counseled private equity firms on FCC spectrum allocation, licensing  and designated entity (DE) bidding credit matters. (Ongoing)

Spectrum licensing, sharing, and transactions for service providers

Advise service providers on potential commercial operations under spectrum sharing regime in 3.5 GHz band. (2016)

Incentive auctions

Advised incentive auction applicants on structure and governance issues to comply with FCC designated entity (D.E.) regulations for historic forward auction component of broadcast incentive auction. (2016)

Regulatory compliance

Counseled wireless service providers on regulatory compliance, including build-out obligations, USF contributions, and related operational matters. (2015)

Spectrum interference enforcement proceedings

Represented wireless service providers and cable operators in Enforcement Bureau proceedings and informal disputes involving spectrum interference issues. (2013)


Shenandoah Tel. acquisition of NTELOS

Buy-side regulatory counsel for acquisition of domestic wireless (CMRS) provider acquiring AWS, PCS, and BRS licenses, and network funding under FCC Mobility Fund and RUS grant. (2016)

Tampnet USA LLC acquisition of Broadpoint Wireless licenses and assets

Buy-side regulatory counsel for acquisition of domestic wireless provider. Secured declaratory ruling under 310(b)(4) for foreign parents’ acquisition and holding of domestic wireless and secured DOJ "Team Telecom" approval of transaction. (2016)

Altice-Suddenlink acquisition of cable broadband provider

Secured FCC and state license transfers, including due diligence and regulatory counseling, concerning acquisition of cable broadband and VoIP assets. Sell-side counsel to Suddenlink Communications in $9 billion transaction with Altice, involving review by FCC and 15 states. (2015)

Acquisition of cable broadband provider

Represented national cable broadband provider in obtaining California PUC consents for acquisition of cable broadband provider, involving significant oppositions during adjudicatory transfer of control proceeding. (2014)

IPC Spectrum acquisition of 700 MHz spectrum

Advised utility on acquisition of 700 MHz licenses for wireless telemetry and smart-grid operations. (2016)

Rise Broadband acquisition of 2.5 GHz spectrum

Advised wireless ISP Rise Broadband on the purchase of EBS spectrum rights in the Xanadoo LLC bankruptcy.


CenturyLink v. T-Mobile

Represented wireless communications provider in FCC Enforcement Bureau adjudication involving network interconnection and intercarrier compensation issues. (2017)

Fairpoint v. Charter

Represented cable broadband provider in network access and pole attachment dispute and adjudicatory proceeding involving issues of fair compensation, regulatory classification, and limitations on jurisdiction. (2015)

Suddenlink v. FiberNet

Secured favorable settlement terms for plaintiff in administrative litigation concerning competitive issues arising from waiver of early termination fees. (2011)

West Virginia PSC v. Shentel Cable

Litigated VoIP classification and related issues before West Virginia Public Service Commission. (2011)

XO Communications v. AT&T California

On behalf of XO Communications, litigated collocation and interconnection rate dispute before California Public Utilities Commission. (2011)

Cricket Communications v. AT&T

Arbitration of interconnection and intercarrier compensation issues with AT&T in multiple jurisdictions (Kentucky, Tennessee, Alabama, Mississippi, North Carolina, South Carolina, and Louisiana). (2010)


Open Internet

Advising broadband providers on matters relating to Open Internet compliance, including implementation of data caps, usage limitations, and transparency disclosures. (Ongoing)

Connect America Fund (CAF)

Successfully defeated numerous overbuild subsidies directed to incumbent telco providers through CAF Phase I and Phase II challenge process. (2015)

Rural Broadband Experiment

Represented several cable broadband and wireless service providers during FCC’s experimental rural broadband reverse auction proceeding. (2014)

Broadband privacy

Advising cable and wireline broadband providers on matters relating to privacy and data security obligations and breach reporting duties related to CPNI and customer proprietary information. (Ongoing)

State attorney general investigations

Counseled cable broadband provider on state attorney general inquiry into broadband and network management practices. (2014)

Special Access/Business Data Services rulemaking

Advocated for cable broadband provider in FCC special access "business data services" rulemaking, including comments and ex parte advocacy regarding same. (2016)

Schools and libraries (E-Rate)

Successfully challenged USAC denial of funding decision to secure release of $5 million in E-Rate funding for wireline service provider. (2014)

Healthcare Connect Fund

Drafted, negotiated, and implemented operational contracts for recipient of funding under Healthcare Connect Fund program. (2014)

Audits, investigations, and inquiries

Secured favorable resolution for cable VoIP operator during informal audit of USF contribution and reporting methodologies. (2013)

Additional Qualifications

  • Cole, Raywid & Braverman LLP, Associate, Washington, D.C., 1999-2006
  • KPMG Peat Marwick, Senior Consultant, 1995-1996
  • Hooper Hooper Owen & Gould, Legislative Assistant,1991-1995
  • U.S. Senate Finance Committee, Chairman Lloyd Bentsen (D-Texas), Clerk, 1989-1991

Professional & Community Activities

  • Federal Communications Bar Association
  • JJ’s Tournament, Inc. – Nonprofit organization in support of funding for autism research
  • Lawyers Serving Warriors – Pro bono assistance to veterans
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