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USDA Announces ReConnect Program Funding Totaling Over $313 Million In 18 States

December 18, 2024 – U.S. Department of Agriculture (USDA) Secretary Tom Vilsack has announced more than $313 million in ReConnect Program funding for broadband projects in 18 states. The funding awards are part of the fifth round of USDA’s ReConnect Program, and will be used to provide high-speed internet services in Alabama, Alaska, Arizona, Arkansas, California, Georgia, Idaho, Michigan, Minnesota, Missouri, Montana, Nevada, New Mexico, Ohio, Oregon, Texas, Washington and Wisconsin. With the announcement, a total of 24 broadband projects received funding – $215,358,764 in grants, $97,973,602 in loans, for a grand total of $313,332,366.


FCC Releases 2025 Reasonable Comparability Benchmarks For Fixed Voice And Broadband  Services

December 13, 2024 – The FCC’s Wireline Competition Bureau and the Office of Economics and Analytics have announced the 2025 reasonable comparability benchmarks for fixed voice and broadband services for eligible telecommunications carriers (ETCs) that receive universal service support and are subject to broadband public interest obligations.

Voice Rates – The reasonable comparability benchmark for voice services is $55.55. This is two standard deviations above the 2025 urban average monthly rate of $30.67. Each ETC providing fixed voice services must certify in its FCC Form 481 that the pricing of its basic residential voice services is no more than $55.55.

Broadband Rates – The reasonable comparability broadband benchmark varies, depending upon the supported service’s download and upload bandwidths and usage allowance. To facilitate benchmark calculations, the Office of Economics and Analytics will post an Excel file with a tool in which providers can enter the relevant variables to determine the benchmark for specific service characteristics.

Minimum Usage Allowance – For rate-of-return carriers receiving model-based support, the Bureau adopts a minimum monthly usage allowance of 720 GB for 2025. For carriers receiving support from the Rural Digital Opportunity Fund (RDOF), the minimum usage allowance is either (i) the greater of 250 GB or the average usage calculated by the Bureau for the Minimum and Baseline tiers, or (ii) 2 Terabytes (TB) for the Above-Baseline and Gigabit tiers. For ETCs not subject to the 2 TB minimum usage allowance, the reasonable minimum monthly usage allowance for 2025 is 720 GB.


USAC Releases New Connect America Fund State Map

December 13, 2024 – The Universal Service Administrative Company (USAC) has released a new Connect America Fund State Map (CAF State Map) that “displays total broadband deployment obligations by location count, total cumulative deployment reported so far by location count and total cumulative funding paid out to date – all on a state-by-state basis – by aggregating data for all carriers participating in the Connect America Fund in each state.” USAC has also launched the new CAF Locations Obligation and Deployment by Speed Tier Search Tool to display details at the Study Area Code (SAC) level about the number of locations that broadband providers have deployed with CAF support at each obligated speed tier and reported to USAC, and the total number of locations that carriers must deploy at each speed tier by the end of the program. USAC’s maps and tools are available on the tools page of the High Cost program site and on the High Cost tools section of the USAC Open Data site.


Another New Record! USF Contribution Factor For First Quarter Of 2025 – 36.3 Percent

December 12, 2024 – The FCC’s Office of Managing Director (OMD) has announced that the proposed universal service fund (USF) contribution factor for the first quarter of 2025 will be 36.3 percent. If the FCC takes no action on the proposed USF contribution factor within 14 days, it will be declared approved.

The 36.3 percent contribution factor for 1Q 2025 sets a new record, beating the previous all-time high of 35.8 percent during 4Q 2024. There has now been an increase to the USF contribution factor for three consecutive quarters (2Q 2024 – 32.8%; 3Q 2024 – 34.4%; 4Q 2024 – 35.8%; 1Q 2025 – 36.3%). Historical information on quarterly universal service fund contribution factors is available online from the FCC.

For the first quarter of 2025, the Universal Service Administrative Company (USAC) projects $8.176992 billion in total interstate and international end-user telecommunications revenues will be collected ($7.972750 billion in collections were projected for 4Q 2024). USAC estimates that $2.161100 billion is needed to cover the total demand and expenses for all Federal universal service support mechanisms (revenue requirement) in the first quarter of 2025 (the 4Q 2024 demand was estimated at $2.084640 billion). Total first quarter 2025 demand includes projected program support, administrative expenses, and true-ups and adjustments, which breaks out among the USF support mechanisms as follows:

  • E-Rate Schools & Libraries:  $657.15 million (4Q 2024 was $666.28 million)

  • Rural Health Care:  $129.50 million (4Q 2024 was $150.05 million)

  • High-Cost:  $1.08640 billion (4Q 2024 was $1.06994 billion)

  • Lifeline:  $288.05 million (4Q 2024 was $198.37 million)


North Alabama Electric Cooperative Wants Waiver Of RDOF Default Penalties

December 12, 2024 – North Alabama Electric Cooperative has filed a petition waiver requesting the FCC waive the Rural Digital Opportunity Fund (RDOF) default penalties. NAEC defaulted on its winning RDOF bids for five census block groups (CBGs) while maintaining 21 other CBGs for which it won RDOF support. In its waiver petition, NAEC claims “good cause and special circumstances exist to reduce the penalties associated with NAEC’s early surrender of five of the 26 CBGs where it was awarded funding because: (1) NAEC’s earlier surrender has allowed these areas to be eligible for other federal and Alabama broadband funding; (2) the surrender will ensure that RDOF funds are not spent to duplicate construction in areas that are or will be substantially served by ongoing initiatives of other broadband providers, thereby conserving limited universal service support and enabling the Commission to redirect limited funds to where they are needed most; and (3) the millions of dollars in penalties that NAEC would otherwise face for its surrender of five CBGs early on in the buildout phase of the program is neither reasonable nor proportionate to the harm caused by the default, and if imposed will strain NAEC’s ability to meet it buildout and service commitments for the remaining 21 CBGs that it was awarded.”


FCC Requires Over 2,400 Voice Service Providers To Cure Deficiencies In Their Robocall Mitigation Database Certifications

December 10, 2024 – The FCC’s Enforcement Bureau has issued an Order that directs over 2,400 voice service providers to cure the deficiencies in their Robocall Mitigation Database (RMD) certifications, and notify the Enforcement Bureau that the deficiencies have been cured or file a response explaining why their certifications should not be removed from the RMD. According to the Enforcement Bureau, each company’s RMD certification is deficient because (a) a robocall mitigation plan was not provided or the plan lacks newly-required information; and (b) the certification lacks newly-required information. If a company’s RMD certification is removed, all intermediate providers and voice service providers will be prohibited from accepting traffic from the company. Each of the over 2,400 voice service providers must provide a response to the Bureau no later than 14 days after a summary of the Order is published in the Federal Register.


Commnet Wireless Defaults On Two RDOF Census Block Groups In Idaho & Washington

December 9, 2024 – Commnet Wireless, LLC has notified the FCC’s Wireline Competition Bureau that it is defaulting on Rural Digital Opportunity Fund (RDOF) support for two Census Block Groups (“CBGs”), one each in Idaho and Washington. Commnet Wireless was awarded RDOF support to provide Above Baseline Internet service in each of the Idaho and Washington CBGs. Commnet Wireless has decided to default on the two CBGs because the deployment costs have increased dramatically, and as a result of that and other factors, its “planned RDOF deployment projects in these CBGs are not viable.”


FCC Chair Circulates Declaratory Ruling On CALEA Cybersecurity Requirements & NPRM On Cybersecurity Risk Management Plans

December 5, 2024 – Federal Communications Commission (FCC) Chairwoman Jessica Rosenworcel has circulated to her fellow commissioners a draft Declaratory Ruling that if adopted, would declare that Section 105 of Communications Assistance for Law Enforcement Act (CALEA) affirmatively requires telecommunications carriers to secure their networks from unlawful access or interception of communications. Accompanying the Declaratory Ruling is a Notice Of Proposed Rulemaking (NPRM) that seeks comment on implementing an annual certification requirement for communications service providers to create, update, and implement cybersecurity risk management plans and annual certify compliance with these plans to the FCC. The NPRM also requests public comment on expanding cybersecurity requirements across a range of communications providers, and identifying additional ways to enhance cybersecurity defenses for communications systems. According to the FCC, both items are an effort to address vulnerabilities in U.S. telecommunications networks that were exposed following the Salt Typhoon cyberattack, a sophisticated intrusion linked to foreign state-sponsored actors.


Final Agenda For FCC Open Meeting On December 11, 2024

December 4, 2024 – The Federal Communications Commission has released the final agenda for its next open meeting set for Wednesday, December 11, 2024.

Expanding Unlicensed Use of the 6 GHz Band – The Commission will consider a Third Report and Order that would expand unlicensed use of the 6 GHz band by very low power devices in two additional sub-bands, making a contiguous 1200 megahertz of spectrum available for use by these devices. (ET Docket No. 18-295; GN Docket No. 17-183)

Broadcast Rule Update – The Commission will consider a Notice of Proposed Rulemaking that would amend its rules for radio and television stations to reflect current application processing requirements, clarify and harmonize provisions, and remove references to outdated procedures and legacy filing systems. (MB Docket No. 24-626)

Facilitating Broadband Buildout – The Commission will consider a Report and Order that would adopt targeted modifications to the requirements for Letters of Credit that recipients of Universal Service Fund (USF) high-cost support awarded through a competitive process must obtain. (WC Docket Nos. 10-90, 18-143, 19-126, 24-144; AU Docket Nos. 17-182, 20-34; GN Docket No. 20-32)

Enforcement Order on Reconsideration – The Commission will consider an Order on Reconsideration of its March 19, 2024, Memorandum Opinion and Order in the UPM Technology, Inc. v. Unigestion Holding, S.A., d/b/a Digicel Haiti, complaint proceeding. (Proceeding No. 23-64)

Enforcement Bureau Action – The Commission will consider an enforcement action.

Enforcement Bureau Action – The Commission will consider an enforcement action.

Enforcement Bureau Action – The Commission will consider an enforcement action.


FTC Settles Investigation Of Gravy Analytics & Venntel For Unauthorized Collection And Sale Of Consumers’ Sensitive Location Data

December 3, 2024 – The Federal Trade Commission (FTC) has entered into a consent agreement with Gravy Analytics, Inc. and its wholly-owned subsidiary Venntel, Inc., which settles the FTC’s investigation of the two companies for alleged violations of the Federal Trade Commission Act. According to an FTC complaint, Gravy Analytics and Venntel business involved “unlawfully tracking and selling sensitive location data from users, including selling data about consumers’ visits to health-related locations and places of worship.” Among other things, the two companies collected consumers’ location data without consent, categorized consumers into audience segments based on sensitive characteristics, such as medical conditions, political activities, and religious beliefs derived from the location data, and sold the data containing these unique persistent identifiers to third parties. Under the FTC’s proposed order settling the investigation, Gravy Analytics and Venntel are prohibited from selling, licensing, transferring, sharing, disclosing, or using sensitive location data except in limited circumstances involving national security or law enforcement. The order also requires the companies to maintain a sensitive location data program designed to develop a list of sensitive locations and prevent the use, sale, license, transfer, sharing, or disclosure of consumers’ visits to those locations.


FCC Reminds RDOF Recipients Of Third Year Buildout Obligations & Notification Requirements

December 2, 2024 – The FCC’s Wireline Competition Bureau has issued a Public Notice that provides guidance to Rural Digital Opportunity Fund (RDOF) support recipients regarding the obligation to notify the Bureau if the RDOF program’s third-year service milestone cannot be met. The third-year service milestone requires RDOF recipients to deploy broadband service to 40% of locations in a state. Any RDOF program support recipient that will not meet its 40% buildout requirement by the end of its third year of support must notify the Wireline Competition Bureau within 10 business days of the third-year service milestone deadline and provide information explaining the expected failure. For broadband providers that were authorized RDOF support in 2021, the third-year service milestone deadline is Wednesday, January 15, 2025. For broadband providers that were authorized RDOF support in 2022, the third-year service milestone deadline is Thursday, January 15, 2026. All notifications must be filed in the FCC’s Electronic Comment Filing System (ECFS) in the RDOF docket, WC Docket 19-126. An RDOF support recipient that does not meet its third-year service milestone will be subject to quarterly reporting and have its support withheld if warranted.


November 2024


President-Elect Trump Names Brendan Carr Next FCC Chair

November 17, 2024 – President-elect Donald Trump has announced he will nominate current Federal Communications Commission (FCC) Commissioner Brendan Carr to be the FCC’s next chairman. Commissioner Carr was appointed to one of the Republican seats on the FCC by Trump in 2017. In an X post online, Carr provided the following response to the news: “Thank you, President Trump! I am humbled and honored to serve as Chairman of the FCC. Now we get to work.” Commissioner Carr’s official FCC bio states that he has worked in communications and tech policy for nearly 20 years. He has held other positions at the FCC, including legal advisor and the agency’s general counsel. Commissioner Carr has previously laid out his priorities as FCC Chairman: The FCC needs to change course and bring new urgency to achieving four main goals: (1) Reining in Big Tech, (2) Promoting National Security, (3) Unleashing Economic Prosperity, and (4) Ensuring FCC Accountability and Good Governance.


FCC Announces Tentative Agenda For Open Meeting On November 21, 2024

November 1, 2024 – Federal Communications Commission Chairwoman Jessica Rosenworcel has announced the following tentative agenda for the FCC’s next open meeting scheduled for Thursday, November 21, 2024:

Updating Security for Vital Infrastructure – The Commission will consider a Notice of Proposed Rulemaking that would undertake the first major comprehensive review of the Commission’s submarine cable rules since 2001. By this proceeding, the Commission seeks comment on how best to improve and streamline its submarine cable rules to facilitate efficient deployment of submarine cables while at the same time ensuring the security, resilience, and protection of this critical infrastructure. (OI Docket No. 24-523, MD Docket No. 24-524)

Enhancing Caller ID Authentication Rules – The Commission will consider a Report and Order that would strengthen its caller ID authentication rules by authorizing the use of third parties in the authentication process subject to limits that ensure accountability for compliance with the STIR/SHAKEN standards. (WC Docket No. 17-97)

Program Originating Boosters – The Commission will consider a Second Report and Order and Order on Reconsideration that would adopt final service rules that will enable FM and low power (LPFM) broadcasters to use FM booster stations to originate program content. (MB Docket Nos. 20-401, 17-105)

Enforcement Bureau Action – The Commission will consider an enforcement action.


October 2024


FCC Notice Of Inquiry To Review Quality Of Customer Support Provided By Cable, Broadband, Satellite TV, & Voice Service Providers

October 23, 2024 – The Federal Communications Commission (FCC) has issued a Notice Of Inquiry (NOI) to review the quality of support that cable, broadband, satellite TV, and voice service providers give their customers. The NOI, adopted by a vote of 3-2, “seeks to build a public record on the current state of customer support and ways that the FCC can further protect families and businesses that rely on these critical services.” Comments are due on or before November 22, 2024. Reply comments are due December 9, 2024. The NOI seeks comment on issues that fall within six separate categories:

  • Simple Cancellation – Providing more cancellation options and better disclosure of cancellation practices at the point of sale and on bills.

  • Automatic Renewal of Service – Ensuring providers obtain explicit customer consent for broadband and voice service providers before automatically renewing a service and/or increasing prices after a trial or promotional period expires.

  • Access to Live Representatives – Helping to avoid bouncing consumers from one call menu list to another in a time-consuming effort to obtain resolution.

  • Installation, Outage, and Service Calls – Extending cable operator installation, outage, and service call rules to also apply to satellite TV, voice, and broadband services.

  • Individuals with Disabilities and Speakers of English as a Second Language – Improving the accessibility of customer service resources for individuals with disabilities.

  • Cable-Specific Issues – Local Franchise Authority Developments; State of Existing Customer Service Standards; and Potential New Customer Service Standards and Enforcement.


Mercury Broadband Defaults On RDOF Awards In Illinois, Indiana, Michigan, & Missouri

October 22, 2024 – Mercury Broadband, LLC has notified the FCC’s Wireline Competition Bureau that it has decided to default on Rural Digital Opportunity Fund (RDOF) awards in census block groups in Illinois, Indiana, Michigan, and Missouri. Specifically, Mercury Broadband has defaulted on its RDOF awards for 34 census block groups in Illinois, 21 census block groups in Indiana, 64 census block groups in Michigan, and 10 census block groups in Missouri. The company made the decision to default partly based on deployment costs that “have increased dramatically since Mercury made its bids in the RDOF reverse auction.” Mercury Broadband will no longer be entitled to receive further RDOF support for the surrendered RDOF-awarded census block groups and will be subject to non-compliance penalties.


Cable One VoIP LLC d/b/a Sparklight Defaults On RDOF Awards In Idaho

October 17, 2024 – Cable One VoIP LLC d/b/a Sparklight has notified the Federal Communications Commission that it is defaulting on its Rural Digital Opportunity Fund (RDOF) awards in the state of Idaho. Sparklight was authorized to receive a total of $3,225,684 in RDOF support over ten years to provide voice and broadband to 863 locations in Idaho. The company claims that its “planned RDOF deployment in Idaho is no longer viable due to unforeseeable costs that have increased dramatically since the conclusion of the RDOF auction.” As a result of its default, Sparklight will no longer be entitled to receive further RDOF support and will be subject to non-compliance penalties.


Fidelity Cablevision Defaults On RDOF Awards In Missouri

October 17, 2024 – Fidelity Cablevision, LLC has notified the Federal Communications Commission that it is defaulting on its Rural Digital Opportunity Fund (RDOF) awards in the state of Missouri. The company was awarded a total of $37,979 in RDOF support over ten years to provide voice and broadband to 39 locations in Missouri. Fidelity Cablevision claims that its “planned RDOF deployment in Missouri is no longer viable due to unforeseeable costs that have increased dramatically since the conclusion of the RDOF auction.” As a result of its default, Fidelity Cablevision will no longer be entitled to receive further RDOF support and will be subject to non-compliance penalties.


FCC Issues Notice Of Inquiry To Review Broadband Data Caps

October 15, 2024 – The Federal Communications Commission (FCC) has issued a Notice Of Inquiry (NOI) aimed at gaining a better understanding of the current state of data caps (also referred to as “usage allowances” or “usage limits”) and whether data caps cause harm to competition or consumers’ ability to access broadband Internet access services. Comments are due on or before November 14, 2024. Reply comments are due December 2, 2024.

The FCC describes data caps as restrictions set by Fixed and mobile broadband Internet access service providers on the volume of bits that a subscriber can transfer during a set period of time. Depending on the type of data cap, when the cap’s amount is exceeded, a subscriber may be subject to higher fees, slower speeds, and suspension or termination of service. In the NOI, the FCC requests comment on the following issues:

  • The current state of data caps for both fixed and mobile broadband Internet service, and how data caps may impact consumers and competition.

  • Why the use of data caps continues to persist despite increased broadband needs of consumers and providers’ demonstrated technical ability to offer unlimited data plans.

  • The current trends in consumer data usage.

  • The impact of data caps on consumers, consumers’ experience with data caps, and how consumers are informed about data caps on service offerings.

  • The impact of data caps on competition.

  • The FCC’s legal authority to take action regarding data caps.


Q Link Wireless CEO Pleads Guilty To Stealing Over $100 Million From The FCC’s Lifeline Program

October 15, 2024 – Q Link Wireless, LLC and its CEO, Issa Asad, have pleaded guilty to conspiring to defraud the U.S. government in connection with a years-long scheme to steal over $100 million from the universal service Lifeline program. Mr. Asad also admitted to defrauding and laundering money from the Paycheck Protection Program (PPP), a government program created to help businesses during the COVID-19 pandemic.

Asad began defrauding the Lifeline program as early as 2012 and continued through at least 2021 “by making repeated false claims for reimbursement, taking and retaining Lifeline funds that it was not entitled to receive, providing false information about its Lifeline customers, and deceiving the FCC about its compliance with program rules. Asad directed these illegal activities and conspired with others to commit the fraud.” When Mr. Asad and other Q Link Wireless employees learned that the Federal Communications Commission (FCC) was investigating them for Lifeline compliance, they “created and provided false records to the FCC to conceal the scam and to continue collecting reimbursement.

As part of a plea agreement, Asad is facing a statutory maximum sentence of 5 years’ imprisonment on Count 1 and 5 years’ imprisonment on Count 2. The exact sentence will be determined by the U.S. District Court for the Southern District of Florida after considering the sentencing guidelines and other statutory factors. In connection with the Lifeline fraud, Asad and Q Link will pay jointly $109,637,057 in restitution to the FCC. Asad will pay $1,758,339.25 in restitution to the U.S. Small Business Administration, and will pay a forfeiture judgment against him of at least $17,484,118.


Final Agenda For FCC Open Meeting On October 17, 2024

October 10, 2024 – The Federal Communications Commission has released the final agenda for its next Open Meeting set for Thursday, October 17, 2024, at 10:30 a.m. in the FCC’s meeting room. The FCC’s meeting is open to the public, but all guests must check in with and be screened by FCC security at the main entrance. All FCC open meetings are streamed live at: www.fcc.gov/live and on the FCC’s YouTube channel.

  • Achieving 100% Wireless Handset Model Hearing Aid Compatibility (WT Docket No. 23-388) – The Commission will consider a Report and Order adopting a 100% hearing aid compatibility requirement for all wireless handset models offered for sale or use in the United States and implementation provisions related to this requirement.

  • Implementation of the National Suicide Hotline Act of 2018 (WC Docket No. 18-336) – The Commission will consider a Third Report and Order and Third Further Notice of Proposed Rulemaking that would adopt rules requiring wireless providers to implement a georouting solution for 988 calls to ensure that the 988 Suicide & Crisis Lifeline can connect callers to geographically appropriate crisis centers based on the caller’s general location. The Third Further Notice would also propose and seek comment on requiring covered text providers to support georouting for covered 988 text messages.

  • Restricted Adjudicatory Matter – The Commission will consider a restricted adjudicatory matter from the Media Bureau.

  • Connect2Health Task Force – The Commission will receive a presentation from the Connect2Health Task Force on updates to maternal health data in the Mapping Broadband Health in America platform.


FCC Announces New Chief Technology Officer Andy Hendrickson

October 3, 2024 – The Federal Communications Commission’s Enforcement Bureau has established a Chief Technology Officer position within the Bureau, and has announced that Andy Hendrickson will fill the role. In his role as Bureau CTO, Mr. Hendrickson will “provide strategic and technical advice on technological developments and issues with respect to the Enforcement Bureau’s work and as part of the ongoing effort to strengthen the Bureau’s technical expertise in support of its privacy, data protection, cybersecurity, and network outage enforcement work.” Mr. Hendrickson also will work with the FCC’s Privacy and Data Protection Task Force on issues such as data breaches of telecommunications, cable, and satellite providers; network outages caused by cyberattacks; and supply chain vulnerabilities involving third-party vendors that service regulated communications providers, including cloud providers.


FCC & DOJ Release Cybersecurity Resource Guide For Schools & Libraries

October 2, 2024 – The Federal Communications Commission and the Department of Education, with the help of the Cybersecurity and Infrastructure Security Agency, have released a resource guide to help schools and libraries evaluate cybersecurity risks and identify their most impactful cybersecurity solutions. The guide is intended to help schools and libraries complete applications for the FCC’s Schools and Libraries Cybersecurity Pilot Program which will provide up to $200 million to selected schools and libraries to defray the costs of cybersecurity equipment and services.


Mergers & Acquisitions: Aristotle Unified Communications Transferring Missouri CAF Phase II Locations To Wisper ISP

October 1, 2024 – The FCC’s Wireline Competition Bureau is seeking public comment on a Section 214 transfer of control application filed by Aristotle Unified Communications Inc. (Aristotle) and Wisper ISP, LLC (Wisper), requesting consent to assign Aristotle’s domestic section 214 authorization for its State of Missouri Connect America Fund (CAF) Phase II auction locations (Assigned Census Blocks) to Wisper. Following consummation, Wisper will assume the deployment, performance, and other obligations for the Assigned Census Blocks. Comments are due on or before October 4, 2024. Reply comments are due October 11, 2024.

Aristotle is an Arkansas corporation that provides voice and broadband service in rural communities using fixed wireless and fiber. Aristotle has been authorized to receive $3,001,544.70 in CAF Phase II support for the Assigned Census Blocks in Missouri to deploy voice and 25/3 Mbps broadband service to 788 locations.

Wisper is a Delaware limited liability company that provides fixed wireless or fiber-based broadband and voice services to approximately 20,000 residential and business subscribers in Arkansas, Illinois, Indiana, Kansas, Missouri, and Oklahoma. Wisper has been designated an Eligible Telecommunications Carrier to receive CAF Phase II support of approximately $220 million to serve 80,149 locations in Arkansas, Illinois, Indiana, Kansas, Missouri, and Oklahoma

Pursuant to an Assignment and Assumption Agreement, Wisper will acquire the Assigned Census Blocks, assets Aristotle has acquired with CAF support, unexpended CAF support, and the right to receive future CAF support. And, Wisper will assume the deployment and performance obligations and any compliance gap consequences associated therewith.