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A Tale of Two Circuits: How Conflicting Rulings on Customer Location Data Will Shape the Future of Telemarketing Compliance

A Tale of Two Circuits: How Conflicting Rulings on Customer Location Data Will Shape the Future of Telemarketing Compliance

Ecommerce Innovation Alliance

August 19, 2025

The telecommunications industry is currently navigating a complex legal landscape, with recent decisions from two different U.S. Courts of Appeals reaching conflicting decisions on critical questions surrounding customer data privacy, agency enforcement powers, and fundamental constitutional rights. The U.S. Court of Appeals for the District of Columbia Circuit has upheld a significant FCC forfeiture order regarding sharing location-based data against Sprint and T-Mobile, while the Fifth Circuit earlier vacated a similar order against AT&T. …

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Forfeiture Orders, Court Battles, and the Complexities of Real-Time Location Data in Fifth Circuit's Landmark Ruling in AT&T, Inc. v. FCC

Forfeiture Orders, Court Battles, and the Complexities of Real-Time Location Data

David Carter

April 30, 2025

A recent decision by the United States Court of Appeals for the Fifth Circuit, vacating a significant $57 million forfeiture order against AT&T, has sent ripples through the telecommunications industry and drawn responses from the FCC in other ongoing court cases. This ruling, and the subsequent reactions, highlight critical questions about agency enforcement powers, constitutional rights, and the practical challenges businesses face complying with location-based regulations in an era of heightened data privacy.…

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