49 Federal Communications Law Journal 551 (1997)
Following a worldwide trend of increased market competition in telecommunications, both the United States and Germany passed new legislation in 1996 aimed at liberalizing communications regulation. Germany passed the Telekommunikationsgestz (TKG), and the United States passed the Telecommunications Act of 1996. The TKG was enacted in response to European Community requirements that Germany open its telecommunications market. While the TKG covers a broad spectrum of issues, five areas stand out as the law's primary focus: licensing, universal service, market-dominant position regulation, interconnection, and rights-of-way. A comparison between the U.S and German laws in these five areas demonstrates the strength and weaknesses of each system. Although the development of the telecommunications industry differed in the two countries, a comparison of the new laws reveals that both countries are moving in a similar direction of increased liberalization.
Kress, Carl B.
"The 1996 Telekommunikationsgesetz and the Telecommunications Act of 1996: Toward More Competitive Markets in Telecommunications in Germany and the United States,"
Federal Communications Law Journal:
3, Article 3.
Available at: http://www.repository.law.indiana.edu/fclj/vol49/iss3/3