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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