Sampling of Net Neutrality Comments Submitted to FCC

by Nicholas Bramble | January 20, 2010 | Uncategorized | 3 Comments

Because it’s rather difficult to search the FCC site for comments on its Notice of Proposed Rulemaking “In the Matter of Preserving the Open Internet / Broadband Internet Practices” (hint: try searching for proceeding # 09-191 and excluding brief comments), I’ve decided to provide a highly unscientific sampling of 25 or so of the more interesting or relevant comments & ex parte meetings I’ve come across. If you notice additional interesting submissions, let me know. I’ll be updating this page with summaries of the comments in question; of course, many of these documents are several hundred pages long, so my summaries won’t capture every nuance of each comment. Still, I hope this will be useful for analyzing the alliances and arguments that are slowly being forged in response to the FCC’s notice. (The groupings below are intended to convey rough similarities in the nature of the organizations, but not necessarily in the *perspectives* of the organizations re the question of net neutrality or any other question.)

  • Free Press (comment)
  • Center for Democracy & Technology (comment)
  • Electronic Frontier Foundation (comment)
    • argues that the FCC lacks any statutory foundation for its rulemaking and seeks to distinguish reasonable network management from efforts to block copyright infringement.
  • Public Knowledge, New America Foundation, Media Access Project, Consumers Union, & Center for Media Justice (comment)
  • Future of Privacy Forum (comment)

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  • Verizon & Verizon Wireless (comment)
  • AT&T (comment)
    • argues that conversion of broadband networks into “dumb pipes” is inconsistent with history of Internet engineering and in fact would render Internet less neutral.
  • Time Warner Cable (comment)
  • Telefónica, S.A. Spain (comment)
  • Comcast (comment)
  • Sprint-Nextel (comment)
  • Verizon + Google joint submission (comment)

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  • Global Crossing (comment)
  • Fiber-to-the-Home Council (comment)
    • seeks to define “reasonable network management” from perspective of several wireline network engineers.
  • Cisco (comment)
    • advocates for cautious case-by-case approach to adjudication, consistent with Comcast adjudication based on Internet Policy Statement, rather than codification of bright-line rules which might not be adaptable to changing business/technology environment.

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  • Timothy Lee (comment)
  • Barbara Esbin (comment)
  • Tim Wu (comment)
    • contextualizes net neutrality by examining historical regulatory perspective towards “close cooperation between America’s most powerful firms and its most powerful information and transportation networks.”

Comments

3 Responses to “Sampling of Net Neutrality Comments Submitted to FCC”

  1. Dima
    January 23rd, 2010 @ 12:06 pm

    Thank you for compiling this list! I think Amazon’s comment could be an interesting addition.

  2. Digest #22 : ::: Think Macro :::
    January 25th, 2010 @ 10:54 am

    [...] basis of truly neutral web.  Nicholas Bramble of the Yale Information Society Project compiled a nice sample of comments from the various [...]

  3. Sampling of Net Neutrality Comments Submitted to FCC : Information Society Project at Yale Law School | The Other Tom Jones
    January 27th, 2010 @ 3:39 am

    [...] Sampling of Net Neutrality Comments Submitted to FCC : Information Society Project at Yale Law Schoo…. Read More [...]

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