Earl W. Comstock

Earl W. Comstock

Member, Eckert Seamans Cherin & Mellott, LLC

Earl Comstock has more than two decades of direct experience with the question of the proper regulatory treatment of broadband Internet access services. He was one of the principal Senate staff responsible for the negotiation and drafting of the Telecommunications Act of 1996 (Pub. L. 104 – 104). During the four years of Congressional debate that led up to the Telecommunications Act, Mr. Comstock served as chief counsel for Senator Ted Stevens (R – AK) and as special counsel for telecommunications on the Senate Committee on Commerce, Science, and Transportation.

In addition to the Telecommunications Act, Mr. Comstock also participated in the negotiation and drafting of the Cable Television Consumer Protection and Competition Act of 1992 (Pub. L. 102 – 385); the Omnibus Budget Reconciliation Act of 1993 (Pub. L. 103 – 66) which created spectrum auctions and commercial mobile services; the Balanced Budget Act of 1997 (Pub. L. 105 – 33) which established the high definition television transition; the Internet Tax Freedom Act (Pub. L. 105 – 277, Division C, Title XI); and the ORBIT Act (Pub. L. 106 – 180), which privatized INTELSAT.

Since leaving Capitol Hill at the end of 1997 Mr. Comstock has been an attorney in private practice and a consultant on telecommunications and Internet policy. He was also President and CEO of COMPTEL, an industry trade organization representing competitive telecommunications and Internet companies, from 2005 to 2007.

With respect to the regulatory treatment of broadband Internet access services, Mr. Comstock testified before the Federal Communications Commission (FCC) during the agency deliberations that led to the Stevens Report; represented EarthLink in the proceedings that led to the Cable Modem Declaratory Ruling and during the legal challenges of that ruling in the U.S. Court of Appeals for the Ninth Circuit and the Supreme Court (National Cable & Telecommunications Assoc. v. Brand X Internet Services, 545 U.S. 967 (2005)); and presently represents Full Service Network and TruConnect in the pending challenge of the FCC’s Open Internet Order in the U.S. Court of Appeals for the District of Columbia Circuit (Case No. 15-1151, which has been consolidated with other challenges under Case No. 15-1063).

Mr. Comstock has recently left the law firm of Eckert Seamans Cherin & Mellott to become general counsel for a start-up company.

  • J.D., George Mason University School of Law, 1992
  • B.A. in Political Science, University of California, Santa Barbara, 1988


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