Upcoming Dates:
December 15 |
The Form 486 deadline for FY 2023 Wave 17. More generally, the Form 486 deadline is 120 days from the FCDL date or from the service start date (typically July 1st), whichever is later. Upcoming Form 486 deadlines are:
Wave 18 12/22/2023
Wave 19 12/29/2023 |
January 8 |
Due date for comments on the FCC’s NPRM (FCC 23-91) on the eligibility of hotspot loans (see our newsletter November 13th). Reply comments will be due January 24th. |
Comment Period Set for Hotspot NPRM:
The FCC’s Notice of Proposed Rulemaking ("NPRM") (FCC 23-91) on the eligibility of hotspot loans (see our newsletter November 13th) has been published in the Federal Register. This sets January 8th as the due date for initial comments and January 24th for reply comments.
Commissioner Simington Calls for Robust US Cyber Trust Mark:
FCC Commissioner Nathan Simington made a strong argument at the Practicing Law Institute’s conference last week expressing the hope that the FCC’s proposed US Cyber Trust Mark program (see NPRM FCC 23-65 and our newsletter of August 14th) would be based on "robust requirements." To grant cyber labels to a class of devices meeting only a "list of vague criteria," Simington argued, would reduce incentives of manufacturers to design, build, and maintain over time, robust cyber safeguards into their online devices. The award of a US Cyber Trust Mark, he believes, should:
[C]reate a legally enforceable contract between the seller and buyer of the connected device. The content of this contract should not just include representations about the product at a snapshot in time—that it uses a particular kind of encrypted communications protocol, that it is capable of being updated, that it supports user authentication, that it has no known vulnerabilities—but also promises about further action that the manufacturer will take, such as that it will provide security patches until at least a particular date, that it will continue to diligently search for vulnerabilities, and that it will maintain the security of any online services that support the product.
It is with a similar hope in mind that a few parties submitted comments on the FCC’s program to move beyond printed cyber labels to include electronic labels that could be read by systems to which such devices seek connections (see initial comments of E-Rate Central, Information Technology Industry Council ("ITI"), and National Electrical Manufacturers Association ("NEMA")).