On August 28, 2018, the FCC’s Enforcement Bureau announced a Consent Decree with Marriott International, Inc. (“Marriott”) to resolve an investigation into unauthorized transfers of wireless radio licenses in connection with Marriott’s acquisition of Starwood Hotels & Resorts Worldwide Inc. (“Starwood”). The civil payment levied against Marriott and the other conditions set forth in the Consent Decree serve as a reminder to companies that may not normally be subject to the FCC’s jurisdiction to thoroughly review the regulatory implications of mergers, acquisitions, or other corporate transactions as part of any due diligence conducted before a deal is reached.

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On August 18, the Federal Communications Commission (FCC) announced a $750,000 settlement with Smart City Holdings, Inc.  (Smart City) to resolve an investigation into the company’s blocking consumer Wi-Fi hotspots at multiple convention center locations across the United States.  To settle the case, Smart City agreed to cease all Wi-Fi blocking, implement a compliance plan and pay a civil penalty.  This is the second time the Commission has imposed a large fine for Wi-Fi blocking at large venues.  Last year the agency reached a similar settlement with Marriott International, Inc.

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