FYI – A month left for comments and replies. Our activists at SavetheInternet.com have already put in more than 15,000 comments (some featured below). While the FCC is well-practiced at snubbing the public view on these issues, it’s important to make your views a part of the public record.

Tim

P2P users blast Comcast in FCC proceeding

By Ken Fisher | Published: January 29, 2008 - 08:14AM CT
http://arstechnica.com/news.ars/post/20080129-p2p-users-blast-comcast-in-fcc-proceeding.html

Two weeks into a Federal Communications Commission public comment period on whether Comcast deliberately degrades P2P broadband traffic, there's no shortage of angry users who feel cheated and want the tampering to stop. Evidence is also mounting that Comcast is blocking more than just P2P traffic.

Related Stories

"On numerous occasions, my access to legal bittorrent files was cut off by Comcast," a systems administrator based in Indianapolis wrote to the FCC shortly after the proceeding began. "During this period, I managed to troubleshoot all other possible causes of this issue, and it was my conclusion (speaking as a competent IT administrator) that this could only be occurring due to direct action at the ISP (Comcast) level."

The comment cycle began on January 14th. It came at the request of net neutrality advocates whose petition to the FCC cited an Associated Press investigation concluding that in some instances Comcast "hindered file sharing by subscribers who used BitTorrent."

The cable giant claims that it has delayed access when usage was high, but has not deliberately singled out any sites or services. But Free Press, Public Knowledge and others groups want the Commission to issue a declaratory ruling on whether the practices with which Comcast and others have been charged violate the FCC's Internet policy statement.

That declaration, issued in August of 2005, said that the FCC "has jurisdiction necessary to ensure that providers of telecommunications for Internet access or Internet Protocol-enabled (IP-enabled) services are operated in a neutral manner."

So far most of the filers in this proceeding have written their own comments rather than rely on Web auto forms. They say they want the Commission to find out what Comcast is really up to.

"If you so much as open a BitTorrent client on a computer on the Comcast network, your entire connection drops to almost a crawl," one filer complains. "Comcast is throttling my connection speed when I am transferring files from work to home," another reports. "They are also interrupting my connections."

And a third: "I have experienced this throttling of bandwidth in sharing open source software, e.g. Knoppix and Open Office. Also I see considerable differences in speed ftp sessions vs. html. They are obviously limiting speed in ftp as well."

And a fourth: "Late during the summer of 2007, I experienced that Comcast's Bandwidth throttling system was affecting Lotus Notes traffic. Several users at my company experienced an inability to communicate with our Lotus Notes email servers if they were uploading over 1mb of data. This problem caused a lot of headache for my company."

Some commenters corroborate charges that the ISP inserts RST packets-the equivalent of a telephone hangup signal-into large file streams that the company doesn't like.

"I believe that Comcast Communications is using an application called Sandvine to insert a proverbial 'dial tone' into a data stream," a commenter writes. "There are security measures put in place to prevent a hacker from sneaking data into a data stream, but as Comcast can monitor those streams they can perfectly forge an RST packet that will be interpreted as coming from the other party."

Another filer agrees:

"I personally feel that Comcast is inserting RST packets into other TCP protocols, not just Bit Torrent," he writes. "We run a custom chat server on port 2001. The connection will never stay up for longer than an hour before the connection is reset. A year or so earlier, this was never the case and our connection would stay up for days on end. When the traffic is encrypted (in an SSH tunnel), the connection stays up, fine."

Ditto, says yet another sysop:

"I suggest that they have selected specific ports that are known to carry sustained high bandwidth traffic and destinations or origins that could not possibly afford to enforce a restraining order and limited that traffic as best they could by rewriting packets to disturb the flow of traffic."

And several filers argue that Comcast's alleged practices already fall under the jurisdiction of a Federal law: the Computer Fraud and Abuse Act.

"I suspect that violating criminal law is sufficient reason for the FCC to regulate comcast's actions," one supporter of this argument writes. "Need we also mention false advertising, and terminating users accounts for passing an invisible and undocumented monthly bandwidth quota?"

Others are less certain of how exactly the FCC or the courts should regulate Comcast's ISP behavior, but they are sure that the Commission-or somebody-should force the company to be honest with consumers about its practices.

"If Comcast's technology is unable to meet the demands of its users and Comcast is forced to slow popular traffic, then maybe they are over selling the service," a commenter says. "This calls into question their advertising model. If they advertise X rates, but only delivery Y rates, then it should be sold as Y."

Another consumer argues that honesty would only be fair, given that "in many places, Comcast (and other cable companies) may be the only high speed provider as DSL is not always available. Until competing services such as Verizon FIOS can reach out, many users are stuck with this level of service."

"I don't like the idea of making an example out of them [Comcast]," he concludes, "but a hefty fine and requiring them to publish their bandwidth caps may mitigate much of this down the road."

Comcast has yet to file a response to any of these user complaints and suggestions. The corporation will probably wait until the comment period of the proceeding ends and the reply-to-comments window opens on February 14th.

February 28th will be the last day to participate in this proceeding. The docket number is 07-52.

=  =  =  =  =  |

Timothy Karr

Campaign Director

Free Press • www.freepress.net 

SavetheInternet.com • www.savetheinternet.com 

201.533.8838



reform media. transform democracy.