Christopher Yoo and Gus Hurwitz Comments on AT&T’s Petition for Preemption and Declaratory Ruling

Christopher S. Yoo & Gus Hurwitz June 28, 2026

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We submit these comments in response to the Wireline Competition Bureau’s Public Notice seeking comment on the Petition for Preemption and Declaratory Ruling filed by AT&T Services, Inc., on May 20, 2026.[1] The same analysis bears directly on the preemption questions raised in the Commission’s pending all-IP transition proceeding, and these comments are therefore filed concurrently as reply comments in WC Docket Nos. 25-311 and 25-208.[2]

Read the full comments here.

[1] Wireline Competition Bureau Seeks Comment on AT&T’s Petition for Preemption and Declaratory Ruling, WC Docket No. 26-125, Public Notice, DA 26-520 (rel. May 22, 2026).

[2] Reforming Legacy Rules for an All-IP Future; Accelerating Network Modernization, WC Docket Nos. 25-311, 25-208, Notice of Proposed Rulemaking, FCC 26-11 (rel. Feb. 19, 2026) (“All-IP NPRM”).