Joseph Farrell filed a declaration with the FCC as an exhibit to a petition by T-Mobile USA requesting an expedited declaratory ruling. The declaration analyzed the possible incentives for a mobile wireless network operator to raise rival costs for wholesale data roaming services, and analyzed several pricing benchmarks that the FCC might consider in resolving disputes about whether contract terms for roaming services meet the ‘commercially reasonable’ standard. Read more in this case study.
September 30, 2015