Kelley Drye

Attorneys & Professionals 

Denise Smith

Special Counsel Email vCard
Washington, D.C.
Phone: (202) 342-8614
Fax: (202) 342-8451

Denise Smith is special counsel in the firm's Washington, D.C. office. Her practice focuses on representing telecommunications companies before federal and state regulatory agencies and courts. In particular, Ms. Smith represents and counsels clients on numerous aspects of the Federal Universal Service Fund program, including enforcement actions, regulatory filing obligations, eligible telecommunications carrier ("ETC") designation applications and other relevant issues.

Ms. Smith provides advice to telecommunications companies, including competitive local exchange carriers, interexchange carriers, Internet service providers, conference calling service providers and providers of interconnected Voice over Internet Protocol services on regulatory and strategic issues. Such advice includes, but is not limited to, issues related to state certifications, service discontinuances, and state and federal agency reporting requirements. Ms. Smith also assists clients with "Team Telecom" review of transactions involving foreign ownership, compliance with security agreements, and drafting of procedural manuals implementing security agreements and letters of assurance.

Ms. Smith represents clients in various state and federal agency proceedings, including certification, enforcement, audit and complaint proceedings. She has drafted complaints, answers to complaints, responses to audit and enforcement inquiries from the Federal Communications Commission (FCC) and Universal Service Administrative Company. Ms. Smith also has assisted clients seeking designation as ETCs, for purposes of receiving Universal Service support, including preparation of state and federal ETC applications and compliance plans and representation in related FCC meetings and state proceedings.

Ms. Smith also counsels clients regarding privacy issues including federal customer proprietary network information ("CPNI") protection and usage regulations, and evaluation and compliance with breach reporting obligations. Ms. Smith has assisted clients in drafting CPNI compliance plans and procedural manuals.

Ms. Smith has represented clients in negotiations of interconnection agreements and related documents with other telecommunications carriers. Ms. Smith also has drafted petitions for review of FCC orders and related procedural court filings.

Representative Experience

Counsel and represent a multinational provider of international telecommunications in all aspects of Universal Service Administrative Company ("USAC") audit.

Counsel and represent multinational telecommunications clients before the FCC in all aspects of process to obtain international section 214 authority including representing clients before federal agencies during "Team Telecom" review process.

Representing multinational telecommunications company in obtaining telecommunications operating authority from 23 state regulatory agencies and the Federal Communications Commission and eliminating unnecessary state operational licenses in several states.

Counsel and represent national telecommunications provider in obtaining telecommunications-related contracts including interconnection agreements and mutual traffic exchange agreements, by negotiation and adoption, with approximately 120 ILECs in over 20 states.

Counsel VoIP, wireless and wireline telecommunications provider clients on state and federal regulatory issues including operating authority certifications, discontinuance of service, and federal regulatory compliance issues such as universal service fund reporting and contributions and customer proprietary network information ("CPNI") compliance.

Advising and representing client before the FCC regarding discontinuance of interstate and international telecommunications service offerings.

Preparing applications and representing client in securing state designation as an eligible telecommunication carrier and obtaining state authorization to provide intrastate telecommunications services.

Counseling clients in proper classification of services and allocation of revenues for Universal Service Fund Form 499-A filings.

Memberships & Associations

Federal Communications Bar Association

Pro Bono

Assisted Hurricane Katrina victim in efforts to contest recoupment of disaster assistance funds received from the Federal Emergency Management Agency. Successfully obtained from FEMA a complete waiver for client of any obligations to repay any disaster assistance funds.

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January 5, 2017

Reminder: FCC Filings Due on or Before February 1, 2017

Kelley Drye Client Advisory


February 23, 2017

8th Annual USF Update Webinar

Kelley Drye Webinar