I. Whether 47 U.S.C. §253 allows a private party to sue a state or local government in equity to preempt a duly enacted state or local regulation where Congress, as part of its comprehensive enforcement mechanism, entrusted the Federal Communications Commission (FCC) with authority to preempt state or local regulations only "to the extent necessary to correct" any violation of or inconsistency with §253, and to do so only after providing notice and the opportunity for public comment. 47 U.S.C. §253(d).

II. If the Court concludes Crown Castle and others may bring equitable actions to preempt state and local regulations under §253, whether §253 preemption reaches measures taken by state and local governments to manage public rights-of-way where the plain and unambiguous language of 47 U.S.C. §253(c) places State and local management of rights-of-way beyond the reach of preemption under §253, and does not limit State and local governments to measures that are nondiscriminatory and competitively neutral.

Whether 47 U.S.C. §253 allows a private party to sue a State or local government in equity to preempt a duly enacted State or local regulation