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Qualcomm’s Objections to the FCC’s Proposed Rules: Summary and Analysis

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In its June 2020 submission to the Federal Communications Commission (FCC), technology giant Qualcomm opposed the FCC’s proposed rules for 5G deployments. In addition, Qualcomm disputed many of the proposed legal, technical and economic rules. This article summarizes the key issues Qualcomm raised in its comments and outlines their practical implications for industry stakeholders.

First, Qualcomm argued that the FCC’s proposal to prioritize 5G deployments would increase deployment costs, particularly for rural locations. The company contends that this will disproportionately impact small businesses and rural customers dependent upon robust networks. Furthermore, it argues that this policy will not incentivize market competition due to a lack of investment from other companies into underserved areas.

Qualcomm also contested the FCC’s interpretation of the 3.5 GHz Citizens Broadband Radio Service (CBRS) band designation on legal grounds. According to Qualcomm, this designation is inconsistent with existing spectrum regulations. It excludes large swaths of users from participating in important 5G applications such as Tactile Internet applications via dynamic spectrum sharing. In addition, they suggested that this could lead to market power abuses among incumbent providers or other companies with deep pockets but limited innovation capabilities.

Finally, they argued against various aspects of the deployment process such as build-out requirements and equipment registration requirements as overly burdensome. Over time, they would stifle innovation within 5G-related markets by discouraging investment from new entrants and small companies. Qualcomm further suggested alternatives such as signing performance requirements which place obligations on all market participants without changing cable-laying regulations or introducing unnecessary paperwork which may have been put in place for legacy technologies only.

Overview of FCC’s Proposed Rules

The Federal Communications Commission (FCC) put forward a set of proposed rules for the wireless industry in March 2021, which attracted strong backlash from Qualcomm.

Qualcomm is one of the leading providers of 5G technology, and it has a lot to lose if the proposed rules are implemented. In this article, we will try to understand why Qualcomm objected to the FCC’s proposed rules.

The proposed rules

The Federal Communications Commission (FCC) proposed rules for the wireless industry in November of 2019. These proposed action items center around increasing the competitiveness and connectivity of 5G networks across the U.S. The rules are to promote greater access to spectrum, promote competition between providers, encourage investments in new technology, and provide regulations that prevent market distortions due to anticompetitive practices by established providers like Qualcomm.

The proposed rules seek to make “multi-band operations” mandatory, which would force competitive wireless providers to acquire and use multiple spectrum bands (or frequencies) with each other’s networks as auxiliary or supplemental carriers. This would help prevent established companies from blocking market entry by using one band as a sole service source, as entire markets can become locked out from multi-band operations due to their minimal coverage in certain sections of the US.

In addition, the FCC has proposed that 5G spectrum auctions should be conducted to eliminate any potential collusion or manipulation among competing bidders and reduce barriers for smaller companies looking to enter into 5G markets by allowing them to obtain spectrum at reasonable costs through bidding. For these proposed policies to be valid, mobile device makers like Qualcomm need to comply with regulations stipulated by the auction process regarding licensing agreements between them and cellular network operators looking to purchase their devices on auctioned spectrum blocks.

The FCC’s proposal would significantly influence Qualcomm’s current business model, given its dominant presence in both cellular network equipment manufacturing and telecommunication network patent licensing. As a result of this proposal’s newfound regulation of licensing practices between Qualcomm and its customers, some stakeholders worry that this could lead Qualcomm’s patent license fees and royalties being reduced drastically – thus decreasing its profit margins substantially if said policies are implemented without proper compensation agreed upon with telecommunications firms or any other interested parties who may be affected by such changes in licensing stipulations.

Potential impacts of the proposed rules

The possible impacts of the Federal Communications Commission’s (FCC) proposed rules on broadband services are wide-reaching, and could potentially have long-term implications for the future of the internet. Of particular concern to Qualcomm is the distinction between mobile and fixed broadband services, and the uncertainty as to whether or not mobile services will be classified as telecommunications services (with regulated rates) or as information services (without regulated rates), as per a reference in The Reasons Behind Qualcomm’s Objections.

Qualcomm’s objections center around several possible unintended consequences of the proposed rules. For example, they argue that emphasizing one type of service over another—if mobile is classified as an information service, while others are not—will create a two-tiered system wherein some technologies have a competitive advantage. Qualcomm also believes that any regulatory action should be applied uniformly across all broadband providers, regardless of technology type. In addition, Qualcomm feels that establishing an “Open Internet Order” could place an unnecessary financial burden on smaller providers who lack large capital reserves to invest in infrastructure upgrades necessary for ensuring maximum quality of user experience.

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Finally, particularly concerning from Qualcomm’s perspective is the difficulty in gathering full subscriber data to support cost allocation decisions under both Telecommunications and Information Services scenarios. As a leader in 4G/LTE modem chipsets and other wireless systems technology, Qualcomm is positioned to understand how matters such as coverage area considerations can affect which customers receive which services under which rate plans and at what cost points; so being obligated to reconcile customer behavior against multiple rate plans may considerably add complexity to Qualcomm’s operations and customer relations efforts.

The Reasons Behind Qualcomm’s Objections

Qualcomm, the world’s leading wireless chipset manufacturer, recently petitioned the FCC asking them to withdraw their proposed rules for 5G spectrum auctions.

In their petition, Qualcomm argues that the proposed rules would reduce competition, discriminate against some service providers, and cause uncertainty in the market.

This article will cover the reasons behind Qualcomm’s objections to the FCC’s proposed rules and provide a summary and analysis of that information.

Qualcomm’s opposition to the proposed rules

Qualcomm is one of the biggest players in the mobile device industry and has been vocal in their opposition to the FCC’s proposed net neutrality rules. They argue that these proposed rules will damage the consumer telecom market and small businesses that rely on data services.

Qualcomm’s main argument is that these proposed rules would burden companies unnecessarily, effectively making them into public utilities. Qualcomm also claims that net neutrality would limit its ability to innovate by removing incentives for companies like themselves to invest in new technologies.

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The proposed rules ensure that companies do not prioritize certain traffic over other types or block access to certain websites. However, Qualcomm believes this could stifle new markets and reduce competition as larger organizations have better resources than smaller ones. In addition, this could lead to a decreased service availability for consumers due to a lack of variety and potentially increased prices for internet use.

Finally, Qualcomm objects that the FCC’s proposal does not definitively protect consumers from discriminatory practices or specific violations of net neutrality by ISPs. If approved, this could result in consumer confusion about who is responsible for any breaches of net neutrality protection and what recourse may be taken if an ISP provider abuses or neglects these rights.

Qualcomm’s arguments against the proposed rules

The Federal Communications Commission (FCC) released proposed rules in February, which would determine the technical standards and usage regulations for wireless communications, like those provided by Qualcomm. The proposed rules would affect how spectrum is allocated for commercial and non-commercial use, and could potentially limit the type of technology products used in certain areas.

In response to the FCC’s proposals, Qualcomm has argued that the proposed rules will put telecommunications companies at a competitive disadvantage by over-regulating the industry. Qualcomm also objects to certain provisions of the new rules relating to spectrum sharing and access, interference protection requirements, receiver performance standards, and other technical matters.

Following are some of the core points from Qualcomm’s objections:

1. Spectrum Sharing: Qualcomm is particularly concerned about a provision of the FCC’s proposal that would require two licenses for each license holder if there is any possibility of shared access between operators with different blocks of spectrum. This requirement exceeds what is needed to provide interference protection due to cognitive radio technologies, which allows efficient spectrum access without increased licensing costs or interference problems.

2. Interference Protection: Qualcomm believes that maximum power requirements should be lowered to allow more efficient use of currently allocated spectrum via technology like beam forming antenna systems or spatial multiplexing techniques. Lower power requirements incentivize alternative operators such as wireless internet service providers (WISPs) to launch rural wireless services without competing with established operators on cost grounds alone.

3. Receiver Performance Standards: Under current policies on receiver performance levels, large areas are blocked out from new services due to existing users maintaining unnecessarily stringent receiver performance standards which prohibits further investment into those markets even if it can be proven that investments do not cause any increase in interference levels within existing services due to cognitive radio systems capabilities.

4. Access Fees: The FCC proposed rules set a floor price for wholesale acquisitions made between two carriers operating across two blocks of spectrum which allows pricing models normally used by dominant carriers when selling capacity or terminating traffic on their networks; these pricing models overcharge small clients creating an artificial entry barrier from smaller carriers trying enter new markets based on market demand generated higher capacity deployments These fees should take into account incremental changes made within existing customers deployment plans or coverage area when additional users enter the market otherwise competition will suffer both economically and technologically without allowing full exploitation of available potential fleet investments offered by alternative operators.


Qualcomm recently submitted comments to the FCC regarding its proposed rules that could significantly impact the mobile industry. Qualcomm’s objections to the FCC’s proposed rules present a significant challenge to the industry.

In this article, we’ll cover the reasons behind Qualcomm’s objections to the proposed rules and analyze the implications for the industry.

Potential impact of Qualcomm’s objections

Qualcomm has identified their objections to the proposed rules outlined by the FCC regarding their proposed 4G/5G service. Understanding these objections and their potential effect can help stakeholders better evaluate their impact on the market.

Qualcomm suggests that the rules would significantly reduce Lowest Unblocked Surface Area (LUFS) interference on 5G services and could disproportionately negatively affect its high-power, higher service spectrum users. These users are predominantly rural, tribal and educational entities, who rely on bandwidth for essential services and require higher levels of data transmission than is achievable in lower-powered spectrum bands. Qualcomm also worries that it could be subject to additional costs if the rules were enforced due to the “unreasonable” investment required to address interference issues with its existing NRF24L01 radio chipsets.

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The company also contends that it should not be forced to procure additional radio frequency antenna/equipment when it is unnecessary and states that no proof or statistical evidence demonstrates that reducing LUFS leads to increased reliability, coverage or device performance. Additionally, Qualcomm’s claims of an unreasonable cost burden would likely be shared with other spectrum holders if these rules were accepted, driving up cost of operations across all carriers and end users while risking an increase in unsound business practices by older mobile technology providers hoping to squeeze profit from outdated resources.

Finally, Qualcomm warns that implementing these changes would potentially lead providers of older 2G/3G technology to be unable to take advantage of newer 5g technologies – resulting in less competition which could lead to reduced choice for consumers within certain markets as well as stifling innovation as new companies face hurdles in a fewer competitors market place.

Implications of the FCC’s proposed rules

The FCC’s proposed rules could have a wide-ranging impact on the market for wireless services. They could affect the competition among wireless service providers, shifting competitive advantage toward larger companies and placing small businesses at a disadvantage. Likewise, by disrupting existing arrangements between mobile device manufacturers and their suppliers, the proposed rules could push up prices of devices, as well as force device makers to invest in new tools and technologies or vertically integrate their operations to manage changes in supply chains.

The FCC’s proposed rules also undermine research and innovation by expanding government powers over spectrum use and limiting who can access certain frequencies. This could limit Qualcomm’s ability to develop new mobile technologies, including their 5G network equipment designed to provide faster download speeds and use less energy than currently available networks.

Finally, some industry experts have argued that the proposed rules threaten equitable access to Wi-Fi services by allowing companies like AT&T and Verizon to provide more extensive coverage without additional investment –a move that would reduce competition from smaller providers. These implications show why Qualcomm has actively objected to these regulations to benefit them and other industry players.


Qualcomm is one of the leading wireless technology companies and a key player in the ongoing debate around the FCC’s proposed rules. The company has expressed various objections to the proposed rules, focusing on concerns over potential harms to competitive market fairness and spectrum availability. Qualcomm further highlights impacts to existing investments that they have made, as well as potential future disruptions in their relationships with important customers.

These qualms reflect a larger ecosystem-level dispute at play between network operators, over-the-top services providers, and technology companies seeking different outcomes based on their particular interests. While addressing these potential harms and preserving an environment for fair competition must remain top priorities for policy makers formulating public policies, it is also important to ensure that no single stakeholder can truly dominate nor manipulate the market dynamics by putting salient regulatory proposals at risk.

As such, stakeholders from all industries must actively engage to develop solutions that can best manage competing interests while recognizing the importance of balancing innovation versus stability within dynamic technology markets.

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