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Network Neutrality FCC Comments


Photo Credit: Wesley Fryer

Net neutrality is the simple principle that the Internet should be a level playing field. Eliminating net neutrality would stifle competition, speech, and innovation in every industry. More specifically, a net neutrality rule would forbid companies who provide access to the Internet, such as phone and cable companies, from blocking websites and applications, from engaging in application-specific technical discrimination biasing the network in favor of some websites or applications, and from charging new tolls on websites and applications merely to reach users or to have "fast lanes" or other network preferences.

In May, FCC Chairman Tom Wheeler proposed to allow technical discrimination and paid fast lanes. The Chairman's proposal would inhibit innovation, competition, and freedom of expression. The companies which can afford to pay for fast lanes are big, established companies. Little guys—startups, non-profits, average individuals—can't. So fast lanes give incumbents an additional advantage, perhaps a decisive one. That harms both entrepreneurs and consumers, and it puts the Internet—now the most democratic platform for commerce and speech—within the power of of just a few large cable and phone companies.

Who supports Title II? Review the list of supporters.

Below are the FCC Comments filed by a variety of companies.
Click on the links to scroll to that particular section: Businesses · Civil Society · Congress & Public Officials

BUSINESSES

Crowdfunding · eCommerce · Education  · Gaming · ISP & Hosting · Investors · Media · Payment  · Search Engines & Browsers · Social Network  · Video Streaming

Several of America's largest tech companies, including Amazon, Facebook, Google, Microsoft, Twitter, and Yahoo have submitted a letter to the FCC in defense of net neutrality.

CROWDFUNDING

Kickstarter
Kickstarter is an American worldwide crowdfunding platform. The company's stated mission is to help bring creative projects to life. Kickstarter claims it has received over $1 billion in pledges from 5.7 million donors to fund 135,000 projects, such as films, music, stage shows, comics, journalism, video games, and food-related projects.

"Because of Chairman Wheeler's draft proposal, many in the NYC tech community are deeply concerned for the future of their businesses and their jobs."

ECOMMERCE

Etsy
Etsy is a marketplace where people around the world connect to buy and sell unique goods.

"Etsy and our sellers would suffer under any rule that would allow big companies to pay for better broadband access to customers. For example, if Etsy were to enable our sellers to market their products with videos, Etsy may not be able to afford such high-speed access, and the one million micro-businesses that earn income on Etsy would be out of luck."

Gilt
Gilt provides instant insider access to today's top designer labels, at up to 60% off retail.

"...the only way that the FCC can draw that bright line is for the agency to reclassify broadband Internet access service as a telecommunications service under Title II of the Communications Act."

Warby Parker
Warby Parker is an American brand of prescription eyeglasses and sunglasses founded in 2010. Warby Parker sells online, and has a limited number of showrooms in the United States.

"...the only way that the FCC can draw that bright line is for the agency to reclassify broadband Internet access service as a telecommunications service under Title II of the Communications Act."

EDUCATION

General Assembly
Established in early 2011 as an innovative community in New York City for entrepreneurs and startup companies, General Assembly is an educational institution that transforms thinkers into creators through education in technology, business and design at nine campuses across four continents.

"[U]nder the FCC's proposed scheme, General Assembly would not have been able to mature into a company that currently employs over 300 people globally and has helped hundreds of Americans get jobs in the tech sector and acquire the skills to start their own companies..."

Codecademy
Codecademy is an online interactive platform that offers free coding classes in six different programming languages like Python, PHP, jQuery, JavaScript, and Ruby, as well as markup languages including HTML and CSS.

"We're building the basic steps of competency to help people start their own companies, websites, apps, and products and get entry level jobs right now. The next big thing, or an innovative solution to a social problem, could be developed by someone who learned how to code using Codecademy.

But none of that may happen if the FCC adopts its fast-lanes proposal and abandons an open Internet."

CodeCombat
CodeCombat is a multiplayer programming game for learning to code. It was created to make learning fun, even addictive, through fast, extensive practice rather than slow, intensive lessons. CodeCombat's mission is to teach people to code.

"How can small businesses with little to no financial resources survive and compete if they have to spend the time and money to ensure their content is delivered at the same standards as their much larger incumbent competitors?"

OpenCurriculum
OpenCurriculum is a place to create, access and share K-12 learning material.

"When I started the company two years ago, I had less than $500 in my bank account--and did not know if I could afford my rent in a shared sublet the coming month, let alone the cost of any computing infrastructure."

GAMING

Heyzap
Heyzap is a social discovery and monetization platform for mobile games and apps. Heyzap is based in San Francisco and was founded in 2009 by Jude Gomila and Immad Akhund.

"When we founded Heyzap, we had negative bank balances. We could not have afforded to pay to put ourselves in a fast lane."

INTERNET SERVICE PROVIDER & HOSTING

Cogent
Cogent Communications is a multinational internet service provider based in the United States. Cogent's primary services consist of Internet access and data transport, offered on fiber optic, IP data-only network, along with colocation in data centers.

Data Foundry
Data Foundry is a global provider of wholesale data center outsourcing, retail colocation, network services, Internet bandwidth, managed services and disaster recovery services.

INVESTORS

Over 100 VCs and angel investors voiced their concern to the FCC regarding the impact that they expect a retreat from open internet rules would have on internet innovation.

Union Square Ventures
 Union Square Ventures is a venture capital firm based in New York City. They are a small collegial partnership that manages $1B across six funds. Their portfolio companies create services that have the potential to fundamentally transform important markets.

"...the only way that the FCC can draw that bright line is for the agency to reclassify broadband Internet access service as a telecommunications service under Title II of the Communications Act."

Y Combinator
Y Combinator provides seed funding for startups. Seed funding is the earliest stage of venture funding. It pays your expenses while you're getting started.

"Competition is the fuel of the free market. We demand it no only as investors looking to invest in the next multi-billion-dollar American job creator, and not only as entrepreneurs who want to start it, but also as consumers who want to see innovation continue to thrive. Our sector requires a level playing field in order to lead the world, create jobs, and tremendous value for the United States economy."

MEDIA

Automattic
Automattic, Inc. is a web development corporation founded in August 2005. It is most notable for WordPress.com, as well as its contributions to WordPress.

"We...all see the vibrant, open Internet that developed as a result, and the primary goal of any FCC rulemaking should be to preserve this. The only effective way to do so is with anti-discrimination rules, which can only be adopted under Title II."

BuzzFeed
BuzzFeed is a social news and entertainment website. Founded in 2006 in New York City as a viral lab by Jonah Peretti, the company has grown into a global media and technology company covering topics like politics, DIY, animals and business.

"...the only way that the FCC can draw that bright line is for the agency to reclassify broadband Internet access service as a telecommunications service under Title II of the Communications Act."

Contextly
Contextly is a better way for publishers to provide readers with relevant content through related links.

"If we had been subject to the technical discrimination and pay-to-play deals that would be permitted under the FCC's proposal, our company would probably not exist today."

Floor64
Floor64 is an insight company. Their goal is to develop unique and innovative ways for companies to connect, gain insight and move forward.

Golden Frog
Golden Frog is a global service provider committed to developing applications and services that preserve an open and secure Internet experience while respecting user privacy.

Pocket
Pocket helps people save interesting articles, videos and more from the web for later enjoyment. Once saved to Pocket, the list of content is visible on any device — phone, tablet or computer. It can be viewed while waiting in line, on the couch, during commutes or travel — even offline.

Reddit
Reddit is an entertainment, social networking service and news website where registered community members can submit content, such as text posts or direct links. Only registered users can then vote submissions "up" or "down" to organize the posts and determine their position on the site's pages. Content entries are organized by areas of interest called "subreddits".

"If the de facto net neutrality rules in the previous decade were not in place, the reddit platform might not exist. If the Chairman's proposal is enacted today, our operations might have to be curtailed drastically."

Spotify
Spotify is a commercial music streaming service providing digital rights management-restricted content from record labels including Sony, EMI, Warner Music Group and Universal. Music can be browsed or searched by artist, album, genre, playlist, or record label.

"...the only way that the FCC can draw that bright line is for the agency to reclassify broadband Internet access service as a telecommunications service under Title II of the Communications Act."

ThoughtWorks
A community of passionate individuals whose purpose is to revolutionize software design, creation and delivery, while advocating for positive social change.

Tumblr
Tumblr is a microblogging platform and social networking website founded by David Karp and owned by Yahoo! Inc. The service allows users to post multimedia and other content to a short-form blog.

"Because of Chairman Wheeler's draft proposal, many in the NYC tech community are deeply concerned for the future of their businesses and their jobs."

Upworthy
Upworthy is social media with a mission: to make important stuff as viral as a video of some idiot surfing off his roof.

"...the only way that the FCC can draw that bright line is for the agency to reclassify broadband Internet access service as a telecommunications service under Title II of the Communications Act."

PAYMENT

Dwolla
Dwolla is a United States-only e-commerce company that provides an online payment system and mobile payments network.

"The FCC should impose a rule against unreasonable discrimination, relying on Title II of the Communications Act."

SEARCH ENGINES AND BROWSERS

Mozilla
Mozilla is a free software community best known for producing the Firefox web browser. The Mozilla community uses, develops, spreads and supports Mozilla products, thereby promoting exclusively free software and open standards, with only minor exceptions.

"Mozilla recommends the Commission instead use its clear authority under Title II of the Communications Act to adopt enforceable protections.."

Opera
Opera is a web browser developed by Opera Software. Opera runs on Microsoft Windows and OS X operating systems and uses the Blink layout engine. Users of Linux and FreeBSD operating systems must install earlier versions which have the Presto layout engine. Opera editions are available for devices running the Android, iOS, Symbian, Maemo, Bada, BlackBerry and Windows Mobile operating systems, and Java ME.

"The proposal envisions a basic level of service and a fee-based discriminatory tier of priority or preferred service. This is a fundamental departure from the open architecture of the Internet that has enabled network operators to sell Internet access to subscribers."

SOCIAL NETWORK

Meetup
Meetup is a larg network of local groups. Meetup makes it easy for anyone to organize a local group or find one of the thousands already meeting up face-to-face. More than 9,000 groups get together in local communities each day, each one with the goal of improving themselves or their communities.

"Because of Chairman Wheeler's draft proposal, many in the NYC tech community are deeply concerned for the future of their businesses and their jobs."

Foursquare
Foursquare makes apps that help people keep up and meet up with friends, and discover great places. Swarm is for people who want the fastest and easiest way to connect with their friends. The Foursquare app is for explorers who want to know about the best spots, and to share what they've found with others.

"...the only way that the FCC can draw that bright line is for the agency to reclassify broadband Internet access service as a telecommunications service under Title II of the Communications Act."

VIDEO STREAMING

Netflix
Netflix, Inc. is an American provider of on-demand Internet streaming media available to viewers in North and South America, the Caribbean, and parts of Europe (Denmark, Finland, Ireland, the Netherlands, Norway, Sweden, and the United Kingdom), and of flat rate DVD-by-mail in the United States, where mailed DVDs are sent via Permit Reply Mail.

"No rules would be better than rules legalizing discrimination on the Internet."

TouchCast
TouchCast is a foundational technology platform for the future of the video web.

"These so-called fast lanes are nothing more than a form of double taxation on the part of the ISPs who are trying to collect from both ends of their pipes."

VHX
VHX is a direct-to-fan distribution platform built for premium video. We empower artists to sell their work from their own websites, directly to fans.

"...the only way that the FCC can draw that bright line is for the agency to reclassify broadband Internet access service as a telecommunications service under Title II of the Communications Act."

Vimeo
In 2004, Vimeo was founded by a group of filmmakers who wanted to share their creative work and personal moments from their lives.

"...the only way that the FCC can draw that bright line is for the agency to reclassify broadband Internet access service as a telecommunications service under Title II of the Communications Act."

CIVIL SOCIETY

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Access
Access defends and extends the digital rights of users at risk around the world. By combining innovative policy, user engagement, and direct technical support, Access fights for open and secure communications for all.

"The FCC must grab this opportunity to assert its full authority under Title II, and implement strong regulations protecting the open internet and innovation online."

American Association of Retired Persons (AARP)
AARP is a nonprofit, nonpartisan organization, with a membership of more than 37 million, that helps people turn their goals and dreams into real possibilities, strengthens communities and fights for the issues that matter most to families such as healthcare, employment security and retirement planning.

"Unless robust open Internet policies are established, rather than generating benefits for all, Internet technology may instead be shaped for the narrow gain of broadband providers."

American Civil Liberties Union (ACLU)
The ACLU is our nation's guardian of liberty, working daily in courts, legislatures and communities to defend and preserve the individual rights and liberties that the Constitution and laws of the United States guarantee everyone in this country.

"The D.C. Circuit ruling in Verizon v. FCC clearly illustrates that what is missing from the framework contained in the Commission's 2010 Open Internet Order is a Title II telecommunications foundation."

American Library Association and more
The American Library Association (ALA) is the oldest and largest library association in the world, providing association information, news, events, and advocacy resources for members, librarians, and library users.

"The specific proposals in the Notice of Proposed Rulemaking (NPRM) fall short of what is necessary to ensure that libraries, institutions of higher education and the public at large will have access to an open Internet."

Center for Democracy and Technology (CDT)
CDT is a champion of global online civil liberties and human rights, driving policy outcomes that keep the Internet open, innovative, and free.

"Classifying such service as a telecommunications service subject to Title II of the Communications Act would eliminate the specific legal obstacle that proved to be the downfall of the 2010 rules, and thus could provide a stable long-term base of authority for open Internet rules."

Common Cause
Common Cause is the original citizens' lobby, founded in 1970 by John Gardner, and still battling for open, honest and accountable government in Washington, D.C. and in all 50 states.

"Any proposal to allow blocking, discrimination, or paid-prioritization would strengthen incumbent ISPs that possess both the technical ability and financial incentives to act as toll collectors, judges and juries of Internet content and access."

Consumer Federation of America (CFA)
The Consumer Federation of America (CFA) is an association of non-profit consumer organizations that was established in 1968 to advance the consumer interest through research, advocacy, and education.

Consumers Union
Consumers Union is the policy and action division of Consumer Reports. They work with million plus activists to pass consumer protection laws in states and in Congress. They hammer corporations that do wrong by their customers, and encourage companies that are heading in the right direction.

"The market for last-mile Internet access is already controlled by a handful of powerful companies and the largest ISPs are becoming increasingly vertically integrated with programmers. Paid priority arrangements would give ISPs even greater power to determine which services reach consumers, putting them in a position to determine which services will thrive. With control over both the pipes and content, these providers have the leverage and incentive to favor their own content over the programming of their competitors, and to make market entry difficult for new entrants."

Electronic Frontier Foundation (EFF)
The Electronic Frontier Foundation is the leading nonprofit organization defending civil liberties in the digital world. Founded in 1990, EFF champions user privacy, free expression, and innovation through impact litigation, policy analysis, grassroots activism, and technology development.

"EFF believes that market competition should be the first and preferred line of defense for innovators and consumers against abusive ISP practices. Because most Americans have only one or two realistic choices for residential broadband, however, normal market mechanisms may not effectively prevent dominant ISPs from adopting policies that undermine the openness that has characterized the Internet."

Engine
Engine supports the growth of technology entrepreneurship through economic research, policy analysis, and advocacy on local and national issues. We are divided into Engine Foundation and Engine Advocacy.

"The FCC's actions over the past decade, starting with the issuance of the Open Internet Order, have enabled the Internet to flourish. Limitations or exceptions to strict network neutrality such as rules authorizing discrimination by ISPs and rules permitting fast and slow lanes will gravely damage the continued vitality of the Internet. Moreover, it would have a devastating impact on startups, which have always been—and continue to be—key drivers of innovation and job creation."

Free Press
Free Press is a nonpartisan organization fighting for people's rights to connect and communicate. Free Press works to save the free and open Internet, curb runaway media consolidation, protect press freedom, and ensure diverse voices are represented in our media.

"The goal is to preserve the open pathway. The only way to do that is to restore common carriage."

Future of Music Coalition
Future of Music Coalition is a national nonprofit organization that works to ensure a diverse musical culture where artists flourish, are compensated fairly for their work, and where fans can find the music they want.

National Hispanic Media Coalition
The National Hispanic Media Coalition (NHMC) is a media advocacy and civil rights organization for the advancement of Latinos, working towards a media that is fair and inclusive of Latinos, and towards universal, affordable, and open access to communications.

Open Media and Information Companies Initiative (Open MIC)
Open MIC is unique among non-governmental organizations (NGOs) in that it seeks to use private sector and capital market mechanisms to influence corporate media management policies.

"As Investors, we believe classification of broadband Internet service under Title II of the Communications Act would best protect the open Internet as a platform for economic growth and innovation."

Public Knowledge (with Benton and Access Sonoma Broadband)
Public Knowledge is a non-profit Washington, D.C.-based public interest group that is involved in intellectual property law, competition, and choice in the digital marketplace, and an open standards/end-to-end internet.

"To best ensure that it adopts rules designed to protect all of the internet—not just its commercial aspects—the Commission should require that broadband access providers operate as common carriers."

Rural Broadband Policy Group
The Rural Broadband Policy Group is a growing national coalition of rural broadband advocates that emerged from the National Rural Assembly.

"In short, Network Neutrality guarantees rural residents access to  the wealth of opportunities provided by the Internet."

Voices for Internet Freedom
Voices for Internet Freedom work together to protect the open Internet and to fight for affordable and universal Internet access.

"Internet Freedom Supporters urge the Commission to reclassify Internet access service as a Title II telecommunications service."

Writers Guild of America, West
Writers Guild of America, West (WGAW) is a labor union representing film, television, radio, and new media writers.

CONGRESS & PUBLIC OFFICIALS

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Senator Al Franken (D-MN)

"The Open Internet NPRM contemplates a much different world - one in which deep-pocketed corporations could dictate the flow of Internet traffic to serve their own interests. This would hamper the free exchange of ideas, and it would be devastating to innovation and economic growth. The Internet's level playing field would be tilted noticeably in favor of the wealthy few who could afford special access."

Representative Alan Grayson (D-FL)

Senator Bill Nelson (D-FL)

"I am very concerned about reports that the NPRM will presumptively allow "paid prioritization arrangements" as long as they are "commercially reasonable."

Senator Bernie Sanders (I-VT)

Senator Ron Wyden (D-OR)

"Today, net neutrality is what the users of the Internet -- all 2.5 billion of them -- demand. Wired lSPs, often operating as a monopoly or duopoly, however, have demonstrated that they are no longer willing to abide voluntarily by these fundamental network management principles."

City of Los Angeles, CA

"...the Internet's openness will deteriorate severely if the Commission does not craft enforceable rules."

New York & Illinois State Attorney Generals

"This goal [of openness] can be achieved by making the necessary reclassification so that broadband Internet access service is  classified as a "telecommunications service," giving consumers and content providers the protections associated with common carrier services."

City of Philadelphia, PA

"Philadelphia's "information economy" has developed rapidly in the last decade, becoming a major source of growth in small businesses and startups, and the well-paying jobs they can bring. Network barriers limiting high speed access to those who can pay a premium for it will disadvantage these new enterprises and stifle an important engine for the City's economic growth."

Vermont State Attorney General

"The time has come to correct the mistake made over a decade ago: reclassify broadband providers as "telecommunications services" rather than " information services."

Washington State Attorney General

"Allowing Internet service providers to charge content providers for preferential treatment could limit the content choices available to consumers and make it difficult for consumers to access the content of their choice."

Massachusetts Dept of Telecommunications and Cable

Pennsylvania Public Utility Commission

"The Pa. PUC believes that its modified common carriage proposals provide the basis for the consistent formulation and implementation of standards that would not only protect the open Internet but would continue to provide the appropriate economic incentives for the continuous deployment of broadband access network facilities and services throughout the United States with the appropriate support from the federal and state USF mechanisms."