Daily Ex Parte, Aug 26, 2025
Anterix (responding to WB Questions), PEARL (A3SA), Sinclair (Ownership & ATSC 1.0 Sunset), Garmin (IoT Cybersecurity), Sorenson (URD & iTRS Numbering Directory)
Filers
Pearl TV — A3SA, the ATSC 3.0 Security Authority
Sorenson Communications, LLC — TRS User Registration Database (URD) and the iTRS Numbering Directory
Garmin International, Inc. — Internet of Things (IoT) Cybersecurity Labeling Program
Anterix, Inc. — detailed responses to Wireless Bureau questions
Sinclair Inc. — National Cap, Multiple Ownership & ATSC 1.0 Sunset
Pearl TV
Proceeding(s): 16-142
Date of Meeting: August 21, 2025
Date Disseminated: August 26, 2025
Participants: Representing Pearl TV and its allies were Anne Schelle (Managing Director, Pearl TV), Joe St. Jean (Managing Director, A3SA, the ATSC 3.0 Security Authority), Rob Folliard (Gray Media and Board Chair, Pearl TV), and Gerard J. Waldron (Counsel for Pearl TV, Covington & Burling LLP). They met with Erin Boone, Hillary DeNigro, Evan Morris, Maria Mullarkey, Evan Baranoff, Lyle Elder, and Mark Colombo from the FCC's Media Bureau.
Summary of Discussion:
The representatives of Pearl TV and A3SA urged the FCC to promptly issue a Notice of Proposed Rulemaking (NPRM) that establishes a clear path and a "date certain" for the conclusion of the ATSC 3.0 (NEXTGEN TV) transition. They argued that the entire broadcast ecosystem—including consumer electronics manufacturers, converter box developers, retailers, and smaller broadcasters—is awaiting a definitive signal from the FCC on the transition timeline. This uncertainty is hindering investment and commitment to developing and manufacturing new conversion devices like dongles and gateways.
A significant portion of the discussion focused on the role of the ATSC 3.0 Security Authority (A3SA) in the NEXTGEN TV ecosystem. Mr. St. Jean explained A3SA's dual purpose:
To develop a robust content security solution that allows content owners to protect high-value content.
To ensure consumers can access that content with the features and functionality they expect.
Key points made about A3SA's system and operations include:
Market Adoption: The A3SA system has been licensed across six major TV manufacturers and several set-top box manufacturers, resulting in over 15 million NEXTGEN TV receivers currently in the market.
Function: A3SA provides the platform and infrastructure for content security, sets compliance rules, facilitates interoperability between broadcasters and devices, and offers pathways for third-party or self-certification. It applies a uniform and objective set of policies to all manufacturers of a given device type but does not certify individual hardware components or chips.
Technical Compliance and Innovation: The A3SA system is fully compliant with ATSC 3.0 standards. It was the first content protection system developed for ATSC 3.0 and is based on widely used Public Key Infrastructure (PKI) technology. A crucial feature is its ability to deliver content and emergency alerts to devices that are not connected to the internet, ensuring service continuity in the event of an internet connection loss.
Device Support: A3SA supports a wide range of devices, including television receivers, set-top boxes, DVRs, gateways, and dongles. Pearl TV and A3SA emphasized their eagerness to collaborate with manufacturers to introduce more gateway and dongle solutions to the market, but reiterated that the primary obstacle is the market uncertainty resulting from the lack of a definitive transition end date. They believe that an NPRM would stimulate the development of these important and consumer-friendly conversion devices.
In conclusion, Pearl TV urged the Commission to move forward with an NPRM based on the proposals previously submitted by the National Association of Broadcasters (NAB) to provide the certainty needed to complete the NEXTGEN TV transition.
Source: [NOTICE OF EXPARTE, Pearl TV, https://www.fcc.gov/ecfs/document/10825502315653/1]
Sorenson Communications, LLC
Proceeding(s): 03-123, 10-51
Date of Meeting: August 21, 2025
Date Disseminated: August 25, 2025
Participants:
Sorenson Communications, LLC: Alex Slusser
HWG LLP (Counsel for Sorenson): John T. Nakahata
Federal Communications Commission (FCC): Robert Aldrich and Michael Scott (Consumer and Governmental Affairs Bureau)
Summary of Discussion:
Representatives for Sorenson Communications, LLC (Sorenson) discussed inconsistencies between the TRS User Registration Database (URD) and the iTRS Numbering Directory. Specifically, they addressed situations where the two databases do not match regarding which provider is the default provider for a particular video relay service (VRS) user.
Sorenson argued that the current process for resolving these discrepancies is inefficient, as it requires filing an appeal for each individual number with the Administrator. They urged the Consumer and Governmental Affairs Bureau to collaborate with the Administrator to establish a more streamlined default procedure for resolving these mismatches, eliminating the need for individual case adjudication. Sorenson reasoned that since consumers involved in porting have already had their identities verified by the URD process at least once, a default process to synchronize the default providers in both the URD and the iTRS Numbering Directory would be appropriate and secure.
In the same context, Sorenson also requested an interim waiver for two specific requirements, pending the Commission's resolution of Sorenson's October 21, 2022, Petition for Partial Reconsideration on the same topic. The requested waivers are for:
The requirement to remove a user from the iTRS Numbering Directory at the end of the two-week grace period.
The requirement to port the user's number back to the original VRS provider from which they had ported.
Sorenson characterized this forced port-back as a "reverse slam," which they argue is contrary to the Commission's policies governing changes in default service providers. They further asserted that granting this waiver would not create any risk of waste, fraud, or abuse, because a VRS provider cannot be compensated for service minutes until the user fully completes the registration process.
Finally, Sorenson noted that the Administrator is developing a unique identifier for the URD which, once implemented, will eliminate the need to re-verify a user's identity during the porting process, further supporting their case for process reform.
Source: [NOTICE OF EXPARTE, Sorenson Communications, LLC, https://www.fcc.gov/ecfs/document/108251925224522/1]
Garmin International, Inc.
Proceeding(s): 23-239
Date of Meeting: August 21, 2025
Date Disseminated: August 26, 2025
Participants:
Representatives of Garmin International, Inc. met with staff from three different FCC offices in separate meetings.
For Garmin International, Inc.:
Max Ali, Principal Counsel - IP
Mitchell Trope, Staff Software Engineer
Savannah Schaefer, Wilkinson Barker Knauer, LLP (Counsel to Garmin)
FCC Participants:
Meeting with the Office of Chairman Brendan Carr:
Danielle Thumann, Senior Counsel
Adam Chan, National Security Counsel
Meeting with the Office of Commissioner Olivia Trusty:
Will Holloway, Legal Advisor
Meeting with the Public Safety and Homeland Security Bureau:
Renee Roland, Special Counsel, Office of the Bureau Chief
Leon Kenworthy, Chief, Cybersecurity and Communications Reliability Division
Drew Morin, Deputy Chief, Cybersecurity and Communications Reliability Division
Ryan Hedgpeth, Senior Telecommunications Technologist
Ahmed Lahjouji, Senior Electrical Engineer
Tara Shostek, Attorney Advisor
Zoe Li, Attorney Advisor
Summary of Discussion:
The discussion focused on the implementation of the FCC's Internet of Things (IoT) Cybersecurity Labeling Program, also known as the U.S. Cyber Trust Mark. Garmin expressed its support for the program's goal of enhancing the security of consumer IoT products.
The primary concern raised by Garmin relates to the potential for misinterpretation and misapplication of the program's requirements within the federal procurement process. Garmin highlighted that recent Executive Orders (14144 and 14306) will mandate that, by January 4, 2027, vendors supplying "Consumer IoT Products" to the federal government must carry the U.S. Cyber Trust Mark.
Garmin explained that some of its products, particularly in its avionics line, utilize Wi-Fi and Bluetooth connectivity. However, these specialized products are not "Consumer IoT Products" as defined and scoped by the FCC's Report and Order in this proceeding. Garmin is concerned that federal procurement personnel may mistakenly identify these avionics and other non-consumer products as requiring the Cyber Trust Mark simply because they possess Wi-Fi or Bluetooth functionality. This potential confusion could cause significant disruption to the procurement of products that are outside the scope of the program.
To prevent this issue, Garmin urged the Commission to proactively collaborate with the FAR Council and the General Services Administration (GSA). The goal of this collaboration would be to provide clear guidance and clarification to federal procurement officials on the specific scope of "Consumer IoT Products" covered by the labeling requirement. Garmin believes this proactive clarification is necessary to ensure a smooth implementation of the Executive Orders without inadvertently impacting products not intended to be part of the program.
Source: [NOTICE OF EXPARTE, Garmin International, Inc., https://www.fcc.gov/ecfs/document/10825959030494/1]
Anterix, Inc.
Proceeding(s): 24-99
Date of Meeting: July 21, 2025
Date Disseminated: August 25, 2025
Participants: Anterix, Inc., represented by counsel Elizabeth R. Sachs of Lukas Lauria Lantor & Sachs LLP, provided written responses to personnel from the FCC's Wireless Telecommunications Bureau, Mobility Division. The FCC staff who received the material include Roger Noel, Alice Koethe, Nina Shafran, Morgan Mendenhall, Kambiz Rahnavardy, and Joshua Smith.
Summary of Discussion:
This filing follows up on a virtual meeting held on July 21, 2025. In an email dated August 14, 2025, the FCC's Wireless Telecommunications Bureau posed two technical questions to Anterix regarding a previous comment it had filed. The filing provides detailed responses to those questions, focusing on the potential for interference from Anterix's 900 MHz broadband operations to Gogo's uplink spectrum.
The core of the discussion centered on a technical analysis conducted by Pericle, which Anterix submitted to argue that the likelihood of harmful interference is extremely low. The key points from the responses are:
Explanation of Interference Analysis: The FCC requested a more detailed explanation of Pericle's field measurement study concerning potential interference from the Anterix uplink to the Gogo uplink.
Anterix's response, prepared by Pericle, clarified that the analysis used the actual, measured Out-of-Band Emissions (OOBE) from a real-world 5 MHz Sierra Wireless radio (EM7565 module), rather than relying on the less precise maximum emissions allowed by the FCC's emission mask.
It explained that the OOBE figure of -19.77 dBm/MHz (correcting a minor typo to -19.57 dBm/MHz) was derived by scaling the measured power from a 100 kHz bandwidth to a 1 MHz bandwidth. This value represents the potential power that could "leak" into Gogo's spectrum.
A graph from the analysis was explained: it plots the power spectral density of the Anterix signal in Gogo's spectrum (Y-axis) as a function of the distance from the Anterix device to the Gogo uplink receiver (X-axis).
The primary conclusion of the study is that any potential interference becomes negligible (below -167 dBm/Hz) at distances greater than 200 meters from Gogo's uplink receiver.
3GPP Standards and UE Power Levels: The FCC asked which 3GPP standard specifies requirements for mobile/portable User Equipments (UEs) operating at 3W and 10W in band b/n106, and whether Anterix was seeking to change these standards.
Anterix responded that the maximum UE power levels established by 3GPP for its bands are 23 dBm (0.1995 W) and 31 dBm (1.2589 W) for band 106, and 23 dBm (0.1995 W) for band n106.
Anterix explicitly stated that it has no plans to request a change to the maximum UE power levels as currently defined by 3GPP.
Source: [NOTICE OF EXPARTE, Anterix, Inc., https://www.fcc.gov/ecfs/document/10825226416520/1]
Sinclair Inc.
Proceeding(s): 16-142, 17-318
Date of Meeting: August 22, 2025; August 26, 2025
Date Disseminated: August 26, 2025
Participants:
Sinclair Inc.: Patrick McFadden (Senior Vice President, Global Public Policy and Communications)
Federal Communications Commission:
On August 22: Marcus Maher (Office of Commissioner Trusty)
On August 26: Deena Shetler (Office of Commissioner Gomez)
Summary of Discussion:
Patrick McFadden of Sinclair Inc. held two separate video conferences with staff from the offices of Commissioner Trusty and Commissioner Gomez. The discussions covered two dockets: the national television multiple ownership rule and the proposed sunset of ATSC 1.0 television transmissions.
National Ownership Cap and Multiple Ownership Rules (MB Docket No. 17-318): Sinclair noted that its discussion regarding the national ownership cap was consistent with its previously filed comments in the proceeding.
ATSC 1.0 Sunset (GN Docket No. 16-142): The primary focus of the meetings was Sinclair's support for the National Association of Broadcasters' (NAB) petition to set a firm sunset date for ATSC 1.0 transmissions. Sinclair argued that the Commission should move expeditiously on the petition for the benefit of both consumers and broadcasters. The main points raised were:
Stimulating the Device Market: Sinclair asserted that providing certainty with a firm sunset date is the most effective way to spur the market for ATSC 3.0-compatible consumer devices. This would ensure consumers can continue to purchase equipment to receive over-the-air signals after the transition.
Broadcaster Viability: Facing rapidly increasing competition from new platforms, broadcasters need to transition to ATSC 3.0 to diversify revenue streams and ensure they can continue to serve their viewers. Sinclair described ATSC 3.0 as a "game-changing opportunity" and stressed that "time is of the essence."
Call to Action: Sinclair urged the Commission to promptly issue a Notice of Proposed Rulemaking (NPRM) on the matter. This would enable the FCC to establish a comprehensive record in support of a phased sunset of ATSC 1.0 signals, proposing a timeline of February 2028 for the top 55 markets and February 2030 for all remaining markets.
Source: [NOTICE OF EXPARTE, Sinclair Inc., https://www.fcc.gov/ecfs/document/1082634716981/1]