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Rosie Moss

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

Rosie advises clients on a wide range of data privacy and technology regulatory issues, including emerging artificial intelligence compliance matters. She assists clients in complying with federal and state privacy laws and Federal Communications Commission (FCC) regulations. Rosie also maintains an active pro bono practice.

As consumers have embraced “smart home” technology and specifically advanced locks and entryway security systems, some door lock companies have asked permission from the Federal Communications Commission (“FCC”) to use ultra-wideband technology (“UWB”) in their devices.  UWB technology has unique characteristics that can be used to enhance entryway security systems by working with low-power Bluetooth

Continue Reading FCC Seeks Comment on Petition to Update Ultra-Wideband (UWB) Part 15 Rules

In late December 2025, the FCC updated its “Covered List” to add foreign-produced unmanned aircraft systems (UAS), commonly known as drones, and their critical components after an Executive Branch interagency body determined that they pose “unacceptable risks to the national security of the United States and to the safety and security of U.S. persons.” Subsequently

Continue Reading FCC “Covered List” Updated to Include Certain Drones and Related Components, Subject to an Exception

On January 9, the U.S. Supreme Court granted certiorari to resolve a circuit split over the FCC’s authority to impose monetary forfeiture penalties through its administrative process.  The outcome could have significant implications for the FCC’s ability to pursue civil penalties in its enforcement cases.  For more information on the issues at stake, including background

Continue Reading Update: Supreme Court Grants Cert in Cases Involving the FCC’s Monetary Penalty Authority

In 2024, the Federal Communications Commission (FCC) issued fines to four major telecommunications carriers—Verizon, AT&T, Sprint, and T-Mobile—for allegedly failing to protect the geolocation data of their subscribers, which the FCC claimed violated its Customer Proprietary Network Information (“CPNI”) rules. To challenge the action, all four carriers had to first pay the fines, which they did.  They then petitioned for review of the FCC’s decision in various U.S. courts of appeals, arguing that the FCC’s procedure for adjudicating monetary fines violated their right to a jury trial as guaranteed by the Seventh Amendment. Verizon sought relief in the Second Circuit, T-Mobile (which had merged with Sprint) sought relief in the D.C. Circuit, and AT&T sought relief in the Fifth Circuit.

The Second Circuit and the D.C. Circuit held in favor of the FCC, rejecting the carriers’ argument that the FCC violated their Seventh Amendment rights. But the Fifth Circuit reached a different conclusion, holding that the FCC’s procedure did in fact violate AT&T’s right to a jury trial. The FCC (which lost in the Fifth Circuit) and Verizon (which lost in the Second Circuit) each has filed a petition for certiorari at the Supreme Court.

With a 2-1 federal circuit split and two certiorari petitions pending, some are predicting that there is a good chance that the Supreme Court will decide to consider the appeals. The dispute raises a fundamental question about the FCC’s authority to impose monetary penalties through its in-house administrative enforcement procedures. If the Supreme Court grants certiorari, it will be called upon to determine whether the Communications Act violates the Seventh Amendment by authorizing the FCC to order the payment of monetary penalties for violations of the Act, without guaranteeing the right to a jury trial. The resolution of this dispute thus could have significant implications for how the FCC enforces the law against telecommunications carriers and other entities subject to its jurisdiction.

Both petitions for certiorari have been distributed for a January 9, 2026 conference.Continue Reading FCC Privacy Enforcement May Face More Constitutional Scrutiny: Supreme Court Review of FCC CPNI Fines Sought Amid Circuit Split

On December 1, the Washington State AI Task Force (“Task Force”) released its Interim Report with AI policy recommendations to the Governor and legislature. Established by the legislature in 2024, the Task Force is responsible for evaluating current and potential uses of AI in Washington and recommending regulatory and legislative actions to “ensure responsible AI

Continue Reading Washington State AI Task Force Releases AI Policy Recommendations for 2026

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