Federal Communications Commission (FCC) data breach reporting requirements under § 222 of the Telecommunications Act (47 USC § 222); “Customer proprietary network information” & “personally identifiable information”; Whether the FCC’s 2024 Order exceeded its statutory authority; § 201(b); “Practice”; Global Crossing Telecomms, Inc v Metrophones Telecomms, Inc; Whether the FCC had the authority under §§ 225(a)(3) & (d)(1)(A) to impose the reporting requirements on “telecommunications relay services” providers; Whether the 2024 Order violated the Congressional Review Act
In an order, the court voted for rehearing en banc, vacated its prior decision and judgment (see eJournal # 84183 in the 8/28/25 edition), stayed the mandate, and restored the case to the docket as a pending appeal.
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