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John Bowers

John Bowers is an associate in the firm’s Washington, DC office. He is a member of the Data Privacy and Cybersecurity Practice Group and the Technology and Communications Regulation Practice Group.

John advises clients on a wide range of privacy and communications issues, including compliance with telecommunications regulations and U.S. state and federal privacy laws.

In a recently published Notice of Proposed Rulemaking (NPRM), the FCC has proposed a major overhaul of the rules governing use of the Upper Microwave Spectrum.  The notice proposes rules designed to encourage more intensive use in the bands collectively known as the Upper Microwave Flexible Use Service (UMFUS) bands, which are jointly shared by

Continue Reading FCC Proposes Overhaul of Upper Microwave Spectrum Rules

As part of the Federal Communications Commission (FCC)’s “Space Month” initiative, the FCC has released a Notice of Proposed Rulemaking (NPRM) designed to overhaul the existing framework for space and earth station licensing.  The FCC’s stated goal is to create the “friendliest regulatory environment in the world” for the space industry.

The proposed framework would

Continue Reading FCC Proposes “Space Modernization for the 21st Century”: Key Highlights for Industry and Stakeholders

On July 17, 2025, the FCC released a discussion draft of a Report and Order (R&O) that, if adopted, would streamline processing of satellite and earth station applications and make other changes to satellite-related license requirements.  The Commission is scheduled to vote on the R&O – which may be subject to further modifications prior to the vote – at the Open FCC Meeting scheduled for Thursday, August 7, 2025.  Below is a high-level summary of some key changes included in the draft R&O.

  • New Flexibility in Adding Satellite Points of Communication.  The R&O creates a new type of earth station license ─ a “baseline license” ─ that would not require an earth station operator to specify satellite points of communication for the earth station in the initial application.  After receiving its baseline license, an operator could then flexibly add satellite points of communication (i.e., new satellites with which earth stations can communicate) as needed.  Notably, the R&O also would modify the process for adding a point of communication to allow for communications “immediately upon both filing notice . . . and pay[ing] the filing fee.”  This streamlined process means that the notice would be effective unless the FCC acted within 15 days after the filing fee is paid to review and remove the new point of communication. 
    • In addition to streamlining modifications for existing earth station licenses, this revision is intended to support the Ground-Station-as-a-Service (“GSaaS”) business model, whereby “a neutral host establishes connectivity to multiple satellite systems in space.”

Continue Reading FCC Releases Draft Report & Order Streamlining Satellite Licensing Processes

On Tuesday, November 26, the FTC released a proposed settlement order with Evolv Technologies, a provider of AI-enabled security screening systems.  The FTC’s complaint in the matter alleged that Evolv violated Section 5 of the FTC Act by making “false or unsupported claims” about the capabilities of an AI-enabled screening system that it provides to schools and other venues.  Specifically, the complaint asserts that Evolv misrepresented “the extent to which the system will detect weapons and ignore harmless items” more accurately and cost-effectively than traditional metal detectors. 

The FTC positioned its action against Evolv as a continuation of its work under the previously announced “Operation AI Comply,” which we discussed here, to “ensure that AI marketing is truthful.”  The complaint alleges that Evolv made “a very deliberate choice” to market its screening system as involving the use of AI, but that Evolv’s effort to position the screening system as a high-tech “weapons detection” system rather than a metal detector “is solely a marketing distinction, in that the only things that [the screening system’s] scanners detect are metallic, and its alarms can be set off by metallic objects that are not weapons.” Continue Reading FTC Settles Case Against Provider of AI-Enabled Security Systems

On December 5, 2024, the Federal Communications Commission (FCC) announced that its filing requirements were now in place for parties seeking to deploy Supplemental Coverage from Space,  finalizing a new regulatory regime that enables satellite operators to work with wireless provider partners to provide ubiquitous coverage to hard-to-reach users.  This step establishes the administrative requirements for FCC approval of SCS deployments and follows on the heels of a November 26th authorization of the first-ever SCS partnership, a collaboration between SpaceX and T-Mobile.Continue Reading FCC Issues Filing Guidelines for Supplemental Coverage from Space (SCS) Applications; Authorizes SpaceX and T-Mobile to Premiere SCS Deployment

On September 25, the Federal Trade Commission (FTC) announced that it brought five actions against companies it accused of using “artificial intelligence as a way to supercharge deceptive or unfair conduct that harms consumers.”  These actions, which the FTC indicated are part of its new enforcement sweep called “Operation AI Comply,” reflect the FTC’s repeatedly stated intention to exercise its authority under the FTC Act and other rules in connection with AI-related products and marketing claims. 

The five actions rely on a range of FTC authorities and target several different forms of conduct. 

  • DoNotPay: The FTC brought an action against DoNotPay, which purports to offer automated legal services, on the theory that it violated the FTC Act by making false claims that its product could substitute for the expertise of a human lawyer.  A proposed settlement would require DoNotPay to pay $193,000, provide notices to past subscribers, and avoid making claims about its ability to substitute AI for professional expertise without proper evidence.

Continue Reading FTC Announces New Enforcement Actions on Marketing of AI-Enabled Products

On Thursday, July 25, the Federal Communications Commission (FCC) released a Notice of Proposed Rulemaking (NPRM) proposing new requirements for radio and television broadcasters and certain other licensees that air political ads containing content created using artificial intelligence (AI).  The NPRM was approved on a 3-2 party-line vote and comes in the wake of an announcement made by FCC Chairwoman Jessica Rosenworcel earlier this summer about the need for such requirements, which we discussed here

At the core of the NPRM are two proposed requirements.  First, parties subject to the rules would have to announce on-air that a political ad (whether a candidate-sponsored ad or an “issue ad” purchased by a political action committee) was created using AI.  Second, those parties would have to include a note in their online political files for political ads containing AI-generated content disclosing the use of such content.  Additional key features of the NPRM are described below.Continue Reading FCC Proposes Labeling and Disclosure Rules for AI-Generated Content in Political Ads

On March 7, 2024, the Federal Trade Commission (“FTC”) announced amendments to its Telemarketing Sales Rule (“TSR”) to apply certain of its provisions to business-to-business telemarketing calls, and to broaden its recordkeeping requirements.  The FTC also announced a notice of proposed rulemaking (“NPRM”) that would further extend the TSR to cover inbound telemarketing calls involving technical support services. Continue Reading FTC Amends its Telemarketing Sales Rule; Proposes Additional Changes

On February 8, 2024, the Federal Communications Commission (FCC) released a declaratory ruling stating that Telephone Consumer Protection Act (TCPA) restrictions on making phone calls using an “artificial or prerecorded voice” “encompass current AI technologies that generate human voices.”  Therefore, unless an exemption applies, telemarketing calls using an artificial or prerecorded voice simulated or generated

Continue Reading FCC Confirms TCPA “Artificial or Prerecorded Voice” Restrictions Apply to AI Technologies that Generate Human Voices

On January 16, the attorneys general of 25 states – including California, Illinois, and Washington – and the District of Columbia filed reply comments to the Federal Communication Commission’s (FCC) November Notice of Inquiry on the implications of artificial intelligence (AI) technology for efforts to mitigate robocalls and robotexts. 

The Telephone Consumer Protection Act (TCPA)

Continue Reading State Attorneys General to FCC: Subject AI-Generated Voice Calls to TCPA Restrictions