Is an IRU Really an IRU?

Is an IRU Really an IRU?

Everyone talks about indefeasible rights of use, or IRUs, as if they are unique or special.  Reams of FCC and state regulatory orders have been written on them as have fiber agreements, both large and small.  Those statements, however, usually take IRUs for granted.  In other words, they assume  that everyone knows what it is and go from there.

Payment Card Industry Data Security Standard 3.0: Business As Usual?

By | Payment Law Advisor | December 16, 2013
Payment Card Industry Data Security Standard 3.0: Business As Usual?

In the past, critics of the Payment Card Industry (PCI) Data Security Standard (DSS) have alleged that the DSS requirements either (1) provide little more than a minimal baseline for security with a “check-the-box” compliance approach; or (2) are written vaguely so that the Council can retroactively allege non-compliance and impose fees on merchants who claim to have been PCI DSS “compliant” at the time of the breach (see our recent Genesco post).