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Paul B. Hudson
Call me when there is no template and no expert; I'm at my best when breaking new ground.
Paul Hudson advises cable operators and competitive telecommunications carriers of all sizes on contract, regulatory, tax, and risk management issues for video, telephone, broadband, interconnection, and wholesale services. Paul appears regularly before the Federal Communications Commission, state public service commissions, and the Universal Service Administrative Company.
Projects the regulatory classification and consequences of new services and technologies, led the first consumer electronics non-regulatory energy efficiency industry consortiums, drafted successful grant applications for new government programs, and obtained first-time FCC waivers on novel grounds.
Communications contracts, disputes, and fees
Negotiates wholesale and retail telecommunications, interconnection, termination, origination, transport, and peering contracts and commercial disputes. Demystifies the FCC's Form 499 instructions and USAC audits; manages risk related to customer surcharges, wholesale exemptions, and reporting strategies for new services and for companies that have not filed or have underreported.
Develops practical solutions for cable operators and telecommunications service providers subject to FCC, USAC and state regulations and enforcement actions.
Telecommunications Services Contracts
- Negotiates and arbitrates wholesale and retail telecommunications contracts and interconnection agreements.
- Negotiates contract dispute settlements and releases, and has won multimillion-dollar judgments before state public service commissions and in American Arbitration Association proceedings.
- Led three successful Recovery Act broadband stimulus award applications, successful FCC Connect America Fund Phase II and Rural Digital Opportunity Fund bids, and the largest successful application to receive funding in the FCC's Low-Income Broadband Pilot Program.
- Actively engaged with potential bidders for the $42.5 billion Broadband Equity, Access and Deployment (BEAD) Program.
- Manages program compliance for recipients of federal Rural Utility Service and broadband stimulus grants and loans from the federal government.
- Advises on compliance and audits for the FCC Affordable Connectivity Program.
Communications and Energy Regulation of Consumer Electronics Equipment
- Counsels on compliance with FCC Part 15 equipment authorization and labeling requirements for electronic devices and on interference risk management, mitigation, and disputes.
- Advocates for and counsels the cable industry regarding the FCC's regulation of cable equipment, including set-top boxes.
- Represents video and broadband service providers and consumer electronics manufacturers in the management of energy efficiency voluntary agreements for televisions, Internet equipment, and set-top boxes.
- Advocates on behalf of the consumer technology industry to state regulators, the U.S. Department of Energy and Environmental Protection Agency, the European Union Directorate for Energy, and Natural Resources Canada to address energy and resource efficiency without undermining innovation.
Universal Service and Telecommunications Taxes
- Advises on federal and state universal service fund and other tax and fee programs, including their potential application to emerging IP and other new services, wholesale exemption forms, Form 499 and traffic study filings, reporting strategies for companies that previously have not filed or have underreported, USAC audits, and universal service reform proposals.
- Advises companies engaged in stock and asset sales involving licensed telecommunications companies and franchised cable operators, including required approvals from the FCC, state utility commissions, local franchise authorities, Team Telecom and the Committee on Foreign Investment in the United States (CFIUS).
- Advises service providers and school districts regarding participation in the federal Schools and Libraries "E-Rate" and Emergency Connectivity Fund (ECF) programs, including drafting contracts and managing responses to USAC questions and audits.
- Prosecuted successful appeals of E-Rate funding denials in cases before USAC and the FCC, including on issues of valid contracts, competitive bidding, cost-effectiveness, and eligibility of services.
Privacy and Customer Proprietary Network Information (CPNI)
- Developed policies and employee training materials for Customer Proprietary Network Information (CPNI) rules for more than 50 service providers.
- Advises clients on data breach involving customers' private information.
Admitted to Practice
District of Columbia, 1999
U.S. Court of Appeals D.C. Circuit, 2006
J.D., Stanford Law School, 1997
B.A., Political Science, Duke University, 1994
Memberships & Affiliations
- American Bar Association
- Federal Communications Bar Association
- Named one of the "Best Lawyers in America" in Communications Law by Best Lawyers, 2021-present
- Partner, Cole Raywid & Braverman LLP, 2005-2006
- Associate, Swidler Berlin, 1998-2005
- Law Clerk, Hon. Rudi M. Brewster, U.S. District Court for the Southern District of California, 1997-1998
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