Equipment Manufacturers
The ArentFox Schiff Communications & Technology practice represents many of the most creative and cutting-edge equipment manufacturers in the world.
Our Work
Our clients manufacture and deploy equipment used in every sector of the economy, from telecommunications and IoT, public safety and homeland security, mining, lighting, music as well as various other areas
A critical threshold issue for any client is to analyze the extent to which its products and systems are regulated by the FCC as telecommunications or telecommunications services, which can subject the client to substantial regulatory requirements and expense, including for example with respect to the FCC’s Universal Service regime. We help our clients navigate regulatory classification and USF issues potentially applicable to their services, and help guide providers through any required certification or registration requirements. We ensure that our clients understand the implications of such regulatory treatment and help them mitigate those impacts to the extent possible.
During product development, we advise our clients as to the FCC’s equipment authorization policies and procedures and help our clients establish relationships with the most efficient and knowledgeable test labs and telecommunications certification bodies (TCBs), all the while working to ensure the confidentiality of our clients’ proprietary methods and technologies. We educate our clients as to the FCC’s complex regulations governing the operation and marketing of devices - both prior to and after obtaining FCC approval. A detailed understanding of these rules can allow manufacturers, in appropriate circumstances, to obtain competitive advantages with respect to customer demos and limited marketing capabilities even before FCC approval is obtained. Similarly, we are experienced in the area of FCC experimental licensing, a process by which manufacturers can usefully gather critical performance data on prototype devices several months, or even years, before FCC approval and product deployment.
Once FCC equipment authorizations are issued, we ensure that our clients comply with the many rules and procedures that apply to approved equipment, such as labeling, equipment identification, and radio frequency (RF) exposure limits. For our many clients whose operations extend overseas, we advise on FCC rules governing the importation of devices, and we also address foreign telecommunications regulation of client devices.
We have obtained numerous waivers from the FCC when a variation from existing FCC regulatory policy would permit the deployment of more efficient and effective devices. Similarly, we have obtained remarkable success for clients in the FCC rulemaking process by filing comments and meeting with FCC staff and commissioners, to ensure that the FCC’s regulations do not have negative unintended consequences, and conversely to ensure that the FCC’s regulations maximize the public interest benefits that our client’s products are designed to achieve. Our experience in this area has been sought for numerous presentations, including for the Antenna Measurement Techniques Association, the Next Generation Radio Communications & Spectrum Technologies Conference, as well as the Military Antennas and Military Wireless conferences.