when, as a grandmother, she was forced to choose between purchasing medication and communicating with her incarcerated grandson. Mrs. Wright-Reed passed away on January 18, 2015, before fully realizing her dream of just communications rates for all people. (8) After the Federal Communications Commission granted the petition Wright Petition described in paragraph (7), the United States Court of Appeals for the District of Columbia Circuit reversed the Federal Communications Commission by interpreting section 276 of the Communications Act of 1934 ( 47 U.S.C. 276 ) in the case of Global Tel*Link v. Federal Communications Commission, 866 F.3d 397 (D.C. Cir. 2017), in part by constricting the meaning of the word fair and limiting the means by which the Federal Communications Commission can calculate fair, just, and reasonable charges. 3. Technical amendments (a) In general Section 276 of the Communications Act of 1934 ( 47 U.S.C. 276 ) is amended— (1) in subsection (b)(1)(A)— (A) by striking per call