I welcome the opportunity to comment on the BEREC Guidelines on the Implementation by National Regulators of European Net Neutrality Rules. I submit these comments as a professor of law and, by courtesy, electrical engineering at Stanford University whose research focuses on Internet architecture, innovation and regulation. My book “Internet Architecture and Innovation,” which was published by MIT Press in 2010, is considered the seminal work on the science, economics and politics of network neutrality. My papers on network neutrality have influenced discussions on network neutrality all over the world.2 I have testified on matters of Internet architecture, innovation and regulation before the US Federal Communications Commission.3 The FCC’s 2010 and 2014 Open Internet Orders relied heavily on my work. I have not been retained or paid by anybody to participate in this proceeding.
My comment is based on and draws heavily on my existing writings on net neutrality. The papers most relevant to this consultation are attached to this submission. The following text summarizes the key ideas and points to the parts of the papers that contain the relevant, more detailed analysis.