Net Neutrality – Comments to the FCC
October 20, 2010
The FCC recently asked for additional comments in its ongoing proceeding regarding Open Internet Principles. In particular, the FCC sought specific input on whether the openness principles should apply to both wireline and wireless networks.
We submitted comments in response to the FCC’s inquiry supporting application of the Open Internet principles to wireless networks. Relevant portions of the submission are shown below:
There is, and should be, only one Internet. Historically, the Internet has not distinguished between various forms of content or how users access such content. This non-discrimination has allowed consumers and software developers to choose between locations, platforms, and devices, all without complex negotiations with transport networks. This freedom has been a key reason why the Internet is so creative, competitive, and consumer-friendly. Internet users now benefit from this flexibility as they access the Internet across a wide range of devices and access points including 3/4G, WiFi, and wired networks. The wave of new Internet enabled mobile devices, such as the iPhone, iPad, and a broad range of smartphones, including Blackberry, Palm, and Android based devices, will continue to drive exponential increases in mobile Internet access. The central fact is that wireless Internet access is as important as wired Internet access.The increasing importance of mobile networks is not the only reason policy should be network agnostic. Users should not have a significantly different experience as they move back and forth between connection types, and they should not have to be aware that one regulatory regime (applicable to wired and WiFi access) protects their ability to access content of their choosing, while another regime (for mobile wireless) does not. At the end of the day, users are not deciding to access a “wired platform” and then a “wireless platform” – they are simply deciding to access the Internet, and their access to content should not depend on how they happen to connect at any given moment. Given the undisputed importance and growth of wireless Internet access, the value created by keeping all Internet access open and neutral, and user expectations of a single Internet, it is imperative that the Commission protect the entire Internet, not just the wireline portion. The best way to do this is to extend the open Internet principles to wireless providers and protect the Internet, not the network.
We trust the FCC will consider these comments, and the many others like them, in reaching its final decision. You can submit your own comments here.