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[ NNSquad ] Does Disclosure Trump Net Blocking?


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From: David Farber <dave@farber.net>
To: "ip" <ip@v2.listbox.com>
Subject: [IP] Does Disclosure Trump Net Blocking?   relates to AA blocking of
 VOIP by Barbara Esbin
Date: Tue, 16 Sep 2008 16:00:11 -0400


http://blog.pff.org/archives/2008/09/does_disclosure.html

Monday, September 15, 2008

Does Disclosure Trump Net Blocking? 	(previous | next)


The FCC's recent Network Management Order concerning Comcast's  
broadband network management practices purported to establish rules of  
"reasonable" network management in the context of an "adjudication" of  
an advocacy group's "formal complaint" concerning Comcast's treatment  
of P2P traffic on its network. I have written elsewhere about the  
legal and procedural defects of the Commission's approach that I  
believe will doom the action's chances on appeal. Here I discuss one  
relatively unexamined feature of the Order, which is the FCC's  
conclusion that "a hallmark of whether something is reasonable" is  
whether a provider discloses the practice to its customers. What will  
this mean in terms of future FCC enforcement actions?

The bulk of the FCC's analysis of reasonable network management in the  
Order was focused on whether the practice in question interfered with  
a consumer's ability to run applications of their choice, access  
lawful content of their choice, and attach lawful devices of their  
choice over their broadband Internet connection. After finding that  
Comcast's practices concerning P2P traffic violated so-called "federal  
Internet policy" by discriminating among applications and protocols in  
a manner that interfered with its subscribers' P2P uploads (and  
relatedly, according to the FCC, their downloads), the FCC rejected  
the company's arguments that its practices constituted reasonable  
network management. The practices used (DPI and RST injection) were  
faulted as non-standard in the industry, according to the FCC's  
analysis of the views of "experts in the field," and as posing  
"significant risks of anticompetitive abuse" that could be justified  
only if they "further a critically important interest and be narrowly  
tailored or carefully tailored to serve the interest." In Comcast's  
case, the FCC assumed, without deciding that "easing network  
congestion" is a "critically important interest." Comcast's methods  
flunked this strict scrutiny-like test, according to the FCC, because  
they were both under inclusive, by missing some congested times and  
areas, and over inclusive, by interfering with traffic during times of  
no network congestion. The FCC intimated, without either citing record  
evidence of otherwise providing serious competitive analysis, that  
anticompetitive motive was behind Comcast's practices. In the agency's  
"expert judgment," therefore, "Comcast's practices do not constitute  
reasonable network management."

Although the FCC previously had not mandated general disclosure  
requirements for broadband network providers, it claimed that "the  
anticompetitive harm perpetuated by discriminatory network management  
practices is clearly compounded by failing to disclose such practices  
to consumers." The FCC was apparently referring to subscriber use of  
P2P protocols to access on-line video programming services offered by,  
Vuze, whose petition for declaratory ruling was part of the docket in  
which the FCC ruling was homed. The FCC reviewed Comcast's prior terms  
of service disclosures and found them wanting, without addressing the  
adequacy of Comcast's revised (and current) disclosures. It was in  
this context that the FCC stated that "the hallmark of whether  
something is reasonable" is whether a provider discloses it to  
customers, and directed Comcast that if it wished to employ capacity  
limits, "it should disclose them to customers in clear terms." But the  
FCC failed utterly to articulate the reasonship between this  
"hallmark" of reasonableness, and its strict scrutiny test for network  
management practices that would find a practice reasonable only if it  
furthered "a critically important interest and be narrowly tailored or  
carefully tailored to serve the interest." In other words, can a  
network management practice that has the purpose and effect of  
limiting a subscriber's ability to access certain Internet content or  
use a particular Internet protocol-based service such as VoIP, be  
immunized if the provider simply discloses beforehand that it will not  
permit its network to be used for this particular purpose? Admittedly,  
the FCC did not say that disclosure is "the hallmark" of a reasonable  
practice, but it did imply that a provider could limit end user access  
if such limitations were disclosed.

This lack of clarity is not surprising, given the FCC's decision to  
enforce "federal Internet policy" in an adjudicatory proceeding  
against a single broadband network provider rather than through an  
industry-wide rulemaking. It is easy to declare, after the fact, that  
inadequate disclosure of network management practices in a particular  
case "compounded" harm, but it tells us little about the outcome of  
case number two.

Why does this matter? In the Sunday edition of The New York Times, Joe  
Sharkey penned an essay entitled "Internet in the Sky: Surf but Don't  
Call." American Airlines has decided to offer the Aircell in-flight  
broadband Internet access service, called "Gogo." Both the airline,  
which, in this case, arguably is acting as a network provider, and  
Aircell, the ISP and application provider, have determined to block  
use of the Internet connection for VoIP services, even though the  
technological capability is there, to protect the rights of airline  
passengers who do not want to fly across the country in the equivalent  
of a jammed-packed flying phone booth. As the article noted,  
"[w]orried about the in-flight equivalent of road rage, airlines have  
been less enthusiastic about any form of voice-call capability," and  
have reacted by imposing the most restrictive solution: blocking voice  
call capability rather than narrowly tailoring their network  
management practice by say, permitting first and business-class  
customers to use their laptop connections for VoIP, while prohibiting  
it in the more densely-packed "economy" sections of the airplanes, or  
simply setting aside "quiet" sections in each fare class.

Does the "federal Internet policy" newly articulated by the FCC apply  
to American Airlines and/or Aircell as broadband ISPs? Should a  
complaint be filed against the airline and Aircell at the FCC? Does  
American's upfront publication of the VoIP ban to potential customers  
render the practice reasonable even though American chose the most  
restrictive method of achieving its aims? We don't know! But now we  
all have to think a about it. And that is just one of the many, many  
problems with the FCC's ad hoc approach to broadband network  
management issues.


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