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WC 16-106 et al: USTelecom Reply in Support of Protecting the Privacy of Customers of Broadband and Other Telecommunications Services

03.16.2017
Reply Comments

The United States Telecom Association (“USTelecom”) respectfully files this reply in support of its petition for reconsideration (“petition” or “PFR”) of the Commission’s Order.1 Like the Order itself, the oppositions to the petition avoid genuine engagement with the reasons we have given for aligning the Commission’s privacy regime with that of the Federal Trade Commission. The oppositions are thus meritless for the same reason that the Order is a textbook case of arbitrary and capricious decision-making. The Commission should now do what it should have done already: conduct a genuine cost-benefit analysis and revise its rules to avoid unfounded inconsistency with the FTC’s well-established and generally applicable framework.

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