Kurt represents clients before the Federal Communications Commission (FCC) and other government agencies, on a wide variety of domestic and international regulatory and transactional matters.


Representative Matters

  • Counsels clients on wireless telecommunications matters, including: interpretation and implementation of applicable laws, regulations, and policies; availability and valuation of spectrum or channels; preparation and filing of applications and necessary waiver requests for new or modified radio systems; negotiation of purchase or sale of radio licenses; participation in FCC spectrum auctions or other licensing proceedings; compliance with FCC, Federal Aviation Administration (FAA), and other agency technical, operational, environmental impact, reporting, record-keeping requirements; and investigations, hearings, and enforcement proceedings related to compliance with statutory and regulatory obligations. 
    • Clients include: private, government, and common carrier FCC radio licensees; operators of commercial and public safety radio systems designed for mobile radio, paging, cellular, microwave, aeronautical, maritime, earth station, and satellite communications; and tower and antenna structure owners and lessors.
  • Counsels clients on compliance with FCC, FAA, and other federal agency rules governing new tower construction and the collocation of antennas on existing towers or buildings under the National Environmental Policy Act (NEPA), the National Historic Preservation Act (NHPA), and the FCC regulations limiting human exposure to radiofrequency (RF) energy.
    • Clients include: wireless communications operators, infrastructure companies, and other entities that construct, own or lease tower structures as well as FCC licensees that deploy antennas on towers or buildings. Clients also include investors requiring due diligence review of compliance with federal rules related to NEPA and NHPA.
  • Advises clients with respect to FCC regulations governing the testing, demonstration, marketing and authorization of digital and radio frequency equipment or devices. Assists companies with obtaining experimental licenses to conduct operations prior to receiving necessary FCC equipment approvals or to conduct tests of prototype devices or systems. Assists clients with FCC inquiries, investigations, or enforcement actions regarding their compliance with statutory and regulatory obligations.
    • Clients include: manufacturers and developers of mobile radio handsets and transmitter infrastructure; radio frequency devices authorized for use on an unlicensed basis; computers and computing devices; and new or innovative products, technologies, or systems.
  • Advises clients with respect to the revenue reporting and contribution requirements associated with the FCC's support mechanisms, including in particular the Universal Service Fund (USF) Program. Assists clients in connection with inquiries and investigations related to their compliance with the FCC's USF reporting and contribution obligations.
    • Clients include: wholesale providers of telecommunications, resellers of telecommunications, private service operators, system integrators, equipment manufacturers, and software developers. 
  • Assists clients with the preparation and filing of comments and related pleadings in a variety of matters, including FCC rulemaking and rate-making proceedings, contested applications, and rule waiver proceedings.
  • Counsels clients regarding contracts related to wireline and wireless telecommunications service arrangements and tariffs (schedules of rates, terms, and conditions).

Professional Experience

  • General Attorney, Federal Communications Commission, Wireline Competition Bureau, Competitive Pricing Division and Enforcement Division (1984-1987)


  • American Bar Association (ABA)
  • Federal Communications Bar Association (FCBA)


  • AV Peer Review Rating, Martindale-Hubbell's highest ranking by peers for general ethical standards and legal ability



J.D., Columbia Law School

A.B., Georgetown University

Law Journals

Editor, Columbia Human Rights Law Review

Bar and Court Memberships

  • District of Columbia Bar
  • Virginia Bar
  • U.S. Courts of Appeals for the Ninth and District of Columbia Circuits
  • U.S. District Court for the District of Columbia

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