June 12, 2025
VIA ECFS
Marlene H. Dortch, Secretary
Office of the Secretary, Federal Communications Commission
45 L Street NE
Washington, DC 20554
Re: Wireless Telecommunications Bureau Seeks Comment on Verizon’s Petition for Waiver
of the Commission’s Section 27.16(e) Handset Unlocking Rule and Verizon’s Tracfone
Unlocking Commitment
Docket Nos: WT 06-150; WTB 24-186; GN 21-112
Dear Ms. Dortch,
In light of President Trump’s directive to federal agencies to jettison old, outdated, and
counterproductive regulations, we support the Federal Communications Commission’s
efforts in this regard. In particular, we support Verizon’s petition to waive the unlocking rule
and strongly feel that FCC action to remove this burdensome regulation is long overdue.[1]
Some of the signers submitted comments in support of the FCC’s proposal in the
proceeding on Promoting Consumer Choice and Wireless Competition Through Handset
Unlocking Requirements and Policies last year.[2]
Clearing the regulatory underbrush can best be accomplished by strategic policy making
that identifies and eliminates regulations that have outlived their usefulness or, in some
cases, should never have been adopted at all. One regulatory inefficiency that should be
swiftly addressed is the continued existence of the C-Block rules, which include the
unlocking rule and were adopted by the FCC in 2007. Even at that time, the Commission
acknowledged the open access and device unlocking requirements the C-Block rules
imposed were experimental in nature and could present “unanticipated drawbacks. ” Now,
nearly two decades later, those drawbacks have become plainly evident and need to be
addressed.
Today’s wireless marketplace is fiercely competitive, and wireless technologies have
dramatically evolved from what they were 20 years ago, an unlocking mandate continues to
unnecessarily impose unique burdens on what amounts to a single provider that impedes
competition and the benefits it brings to consumers. It has also inadvertently opened a way
for criminals, many of them in other countries, to unfairly profit from American consumers.
The unlocking rule has created a huge law-and-order problem. For example, sophisticated
international organized crime rings have been able to avoid protections against the
trafficking of lost, stolen, or fraudulently obtained devices. They can rake in enormous
profits by illicitly acquiring heavily subsidized U.S. phones and reselling them abroad. This
criminal enterprise costs Verizon and its customers billions of dollars, forces law
enforcement agencies to expend valuable time and resources to pursue handset trafficking
fraud and related criminal activity, and hinder access to subsidized devices for honest U.S.
consumers, including seniors, lower-income families, and workers.
Waiving the unlocking rule as a start – but ultimately going broader to eliminate the C-Block
rules – all of which are clearly unnecessary in the modern wireless market, would benefit
American consumers by giving them access to better deals and blocking devices and
resources from being diverted to bad actors. In accordance with the commendable
mandate from the Trump administration for federal agencies to eliminate unwarranted and
onerous regulations, we strongly encourage the FCC to act as quickly as possible.
Sincerely,
James L. Martin, Founder/Chairman Bret Swanson, Founder
60 Plus Association Entropy Economics
Saulius “Saul” Anuzis, President Mario H. Lopez, President
American Association of Senior Citizens Hispanic Leadership Fund
Steve Pociask, Founder Tom Giovanetti, President
American Consumer Institute Institute for Policy Innovation
Bronwyn Howell, PhD Petrus Potgieter, PhD, Researcher
American Enterprise Institute Institute for Technology and Network Economics
Tom Schatz, President Seton Motley, Founder
Citizens Against Government Waste Less Government
Matthew Kandrach, President Roslyn Layton, PhD, Senior Fellow
Consumer Action for a Strong Economy National Security Institute
(CASE) George Mason University
James Erwin, Executive Director
Digital Liberty
CC: Hon. Brendan Carr, Chairman, FCC
Hon. Anna Gomez, Commissioner, FCC
Click here: Support for Verizon-Tracfone Unlocking Waiver to view the letter as a PDF.
[1] Verizon Petition for Waiver. (filed May 19, 2025), https://www.fcc.gov/ecfs/search/search-
filings/filing/1051935705713
[2] Reply Comments of 60 Plus Association et al., Promoting Consumer Choice and Wireless Competition
Through Handset Unlocking Requirements and Policies, WT Docket No. 24-18 (filed Sept. 16, 2024),
https://www.fcc.gov/ecfs/document/1091603938031/1