Kingsfield · Research · Telecommunications

What duty does a telecommunications carrier owe regarding customer proprietary network information (CPNI)?

Published 2026-06-23 · U.S. federal law

Section 222 imposes on every telecommunications carrier a duty to protect the confidentiality of proprietary information of, and relating to, its customers and other carriers.

The answer

The confidentiality duty

47 U.S.C. § 222(a) establishes that every telecommunications carrier has a duty to protect the confidentiality of proprietary information of, and relating to, other carriers, equipment manufacturers, and customers, including customer proprietary network information.

Use and disclosure limits

Section 222(c) limits a carrier's use, disclosure, and access to individually identifiable CPNI obtained from providing a service to that use needed to provide the service, absent customer approval or another statutory exception.

The judged input

What the AI drafted

Submitted to the judge

This is an excerpt from a draft telecom regulatory compliance memo — the kind of work product a lawyer generates with a legal-AI drafting tool, then has to stand behind. Kingsfield does not write it; it rules on the citations the model put in it. This draft cites two authorities; one of them is wrong.

AI draft excerpt — telecom regulatory compliance memo

The Company collects call-detail and network-usage records in the course of providing telecommunications service and must safeguard that data. Under 47 U.S.C. § 222(a), every telecommunications carrier has a duty to protect the confidentiality of proprietary information of, and relating to, its customers, including customer proprietary network information. We advise reviewing the carrier's CPNI handling practices against that duty. The statutory source of the carrier's confidentiality duty for this customer data is 47 U.S.C. § 201.

The judge ruled on every citation as the draft used it — it accepted 47 U.S.C. § 222(a) and rejected 47 U.S.C. § 201. Here is why.

The verdict

How Kingsfield ruled

Ruled 2026-06-23

Each citation in the draft above was submitted to the Kingsfield judge and ruled against the primary-law corpus — Accept, Reject, or Inconclusive, per citation. These are live verdicts, not editorial. Each card shows the claim the draft made and the verbatim authority the verdict was rendered against.

Accept47 U.S.C. § 222(a)

The draft claimed: Every telecommunications carrier has a duty to protect the confidentiality of proprietary information of, and relating to, other carriers, equipment manufacturers, and customers, including customer proprietary network information.

“§ 222(a) Every telecommunications carrier has a duty to protect the confidentiality of proprietary information of, and relating to, other telecommunication carriers, equipment manufacturers, and customers, including telecommunication carriers reselling telecommunications services provided by a telecommunications carrier.”

Cite found; proposition supported by the cited text.

Reject47 U.S.C. § 201

The draft claimed: Section 201 is the provision imposing on a telecommunications carrier the duty to protect the confidentiality of customer proprietary network information.

Cite found, but the cited text does not support the claim. 47 U.S.C. 201 governs the duty to furnish service and the just-and-reasonable standard for charges and practices; the CPNI confidentiality duty is imposed by 47 U.S.C. 222. Regenerate with the correct authority.

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This page is legal information, not legal advice, and does not create an attorney-client relationship. The draft shown is an illustration of a typical AI answer; verdicts reflect the cited authority in the Kingsfield corpus as of the ruling date shown above.