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<http://arstechnica.com/news.ars/post/20080129-p2p-users-blast-comcast-in-fcc-proceeding.html>
By Ken Fisher<http://arstechnica.com/authors.ars/Caesar> | 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

 *   FCC fines Comcast for fake news 
story<http://arstechnica.com/news.ars/post/20070926-fcc-fines-comcast-for-fake-news-story.html?rel>
 *   FCC to investigate Comcast BitTorrent 
blocking<http://arstechnica.com/news.ars/post/20080108-fcc-to-investigate-comcast-bittorrent-blocking.html?rel>
 *   Evidence mounts that Comcast is targeting BitTorrent 
traffic<http://arstechnica.com/news.ars/post/20071019-evidence-mounts-that-comcast-is-targeting-bittorrent-traffic.html?rel>
 *   Comcast traffic blocking: even more apps, groupware clients 
affected<http://arstechnica.com/news.ars/post/20071021-comcast-traffic-blocking-even-more-apps-groupware-clients-affected.html?rel>
"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<http://arstechnica.com/news.ars/post/20080114-fcc-officially-opens-proceeding-on-comcasts-p2p-throttling.html>
 of net neutrality advocates whose petition to the FCC cited an Associated 
Press investigation 
concluding<http://arstechnica.com/news.ars/post/20071019-evidence-mounts-that-comcast-is-targeting-bittorrent-traffic.html>
 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<http://fjallfoss.fcc.gov/edocs_public/attachmatch/FCC-05-151A1.pdf>.
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<http://arstechnica.com/news.ars/post/20071101-advocacy-group-to-fcc-comcasts-traffic-blocking-defense-is-bogus.html>
 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<http://www.panix.com/%7Eeck/computer-fraud-act.html>.
"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<http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi>. The docket 
number is 07-52.



=  =  =  =  =  |

Timothy Karr

Campaign Director

Free Press * www.freepress.net<http://www.freepress.net>

SavetheInternet.com * www.savetheinternet.com<http://www.savetheinternet.com>

201.533.8838



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