I'm not buying it.
Yes, we as service providers have a right to determine th service level agreements we want to set for the price we decide.

A consumer has always believed that they have an unlimited do anything they want with our connection mentality.

We on the other hand have always had terms of service that nullify the anything you want unlimited mentality.

If we are in disagreement with Comcast's position, then what are we really saying?

We would be saying, "anything goes", we have no control, we can't rate limit.

The free market system, does not tie the hands of the isp, but rather allows us each to set our own service levels and terms of service, and compete based on our own service offerings.

To restrict an isp from making a decision, is in no way the free market system, but rather the regulated system.

I'm with Comcast on this. I do not want to be regulated. Let me live or die on the way I decide to run my network.

Thanks Eje for bringing this to our attention.

My recommendation is to back Comcast.
George

Clint Ricker wrote:
Sam and Matt, very well said.

To the rest: If you are petitioning the FCC in union with the cable
companies and telcos, you are screwing your future and help your
competition.  You can't win by the rules that they make.  The network
neutrality battle could potentially change the service provider economics
enough in very positive directions for you.  This is a politically-charged
enough topic that something interesting may actually happen on this :)

First of all, get more customers!  With enough customers, the
oversubscription on bandwidth becomes much better--you can fit thousands and
thousands of resi customers in a 100Mb/s pipe without dropping, but about
10-20 in a 5Mb/s pipe.   With enough customers, the bandwidth cost per
customer comes down to almost nothing.  If you need to limit a couple of
outlying customers (the ones using 3Mb/s all the time), sure, go ahead.  But
don't hate bit torrent or any other protocol :)  Bit Torrent bandwidth costs
_exactly_ the same price as http bandwidth.

I really don't agree with a business philosophy that fundamentally sees it
as a bad thing if people are actually using your service :).  Embrace it and
figure out how to make it profitable (hint--spend more time getting new
customers and less time trying to shave costs).   The bandwidth math is MUCH
better with 1,000 customers than a hundred and MUCH better with 10,000 than
a 1,000.

To everyone thinking that there needs to be "network neutrality"
requirements for big guys, but little guys should be allowed to block: do
you really want to send the message to your (potential) customers: hey--my
competition will let you run the service you want, I won't.

This is an opportunity to actually get ahead of the game and have a leg up
on your competition.  Here are the facts as I see them (applies to the
residential market only):

1. The cost of bandwidth for telcos and MSOs is really extremely low on a
per customer basis.  The bulk of their cost--and why this is a big issue for
them--is the cost of getting that bandwidth to the customer.  For these
guys, the major cost is in the transport networks: fiber buildout is
extremely expensive, transport gear is incredibly expensive, etc.  WISPs
have ridiculously cheap transport networks and, with enough scale, don't
really pay much more for bandwidth.  If you get scale, your bandwidth costs
also drop.  In other words, once you hit a certain scale, your cost of
delivering service becomes much less than your competition.
2. You can't compete on price with a telco/mso doing triple play.  The
economics aren't there.  You don't offer video.  Your customers want video.
They want to be able to watch House and CSI and Dancing with the Stars.
This means that even if they keep you for Internet access, they will sign up
for television service.  They will then, every month, get offers for bundled
video + data services (and sometimes voice) for prices that you can't
compete with.
3. Your competitors can't compete in price without subsidizing their network
buildout with revenue from overpriced, monopolistic telephony and video
solutions.  If/When the Internet becomes _the_ medium for delivering this,
you can adapt to that by...the end of this week.  Your competition will take
years and years to get to this point and fight it every step of the way.
From a revenue / cost standpoint, they simply cannot survive in such an
environment.

However, if people use Joost and Vuze and whatall, then they can use YOUR
connection and no longer have a need to get their video services elsewhere.
Embrace this.  Advertise this.  Help your customers find video services
online.  Make a portal for this.  Start mailing your customers (and your
competitor's customers!) and saying "Bob's Internet: includes over 10,000
video channels for free" and "Bob's three step guide to saving $800 per
year: (step 1: get Bob's Internet, step 2: Tell your cable company "bye-bye"
step 3: Enjoy 10,000 video channels on Bob's Internet Access).

Get your customers thinking: "I can watch CSI and so forth on the
Internet".  You take a data customer away from a cable company...big deal.
You get a community converted to watching their video on the Internet and
the math changes DRASTICALLY in your favor.  You are trying to compete using
a business model that revolves around a $30-$40 average monthly revenue per
customer against providers who have $100-$250 average monthly revenue per
customer.  Attack that!  They simply can't afford to be profitable on a
single pipe / single service model--you can.

Remember, the late 90s were a golden era for independent ISPs because they
got ahead of the curve.  Most of you are, quite bluntly, behind the curve
now.  This is an opportunity to get ahead of the curve

Comment on this to the FCC--just comment in favor of Network Neutrality.
Believe it or not, you will do MUCH better under this model than your
competition because it very much favors your business model and is
incredibly harmful to your competitor's business model.  If you question my
math, feel free to contact me offl-list--there are some specifics that I'm
not willing to discuss in a public forum.

Thanks,
Clint Ricker
-Kentnis Technologies





On Nov 18, 2007 10:44 PM, Matt Larsen - Lists <[EMAIL PROTECTED]> wrote:

My strong feeling is that the free market approach is by far the best
approach to the Network Neutrality/Network Management.  If Comcast wants
to degrade the service to their customers, then that is an opportunity
for the other providers in the market - they are essentially degrading
their own service, especially if they are doing it in a way that
"breaks" specific applications.   In markets where there is a monopoly
or duopoly  and both providers engage in purposefully breaking specific
applications, leaving the customer with no choices, the market condition
is a result of poor regulatory policy - not poor network management.
Competition will take care of that problem.  The few remaining
independent ISPs have this as one of the few potential advantages that
they can bring to the table - a truly different type of service, with
the concerns of the provider and the customer in balance and appropriate
for both parties.  The issue that Vuze seems to be taking is that
breaking of applications is unacceptable, but good network management is
fine, as long as it doesn't discriminate against specific applications
or protocols.

I do take issue with the characterization of Vuze/BitTorrent as being a
"parasite" on our networks.   They are not forcing the customer to use
them for content - our customers paid for connectivity to the Internet,
and should be able to use that connectivity for whatever they want to,
in a way that does not degrade the performance of the network.   It is
the responsibility of the network operator to deploy the network is a
way to deliver appropriate levels of service,  establish clear
definitions of the different levels of service and communicate the
differences to the customers so that they know what they are getting.  I
personally love Vuze, I use it to get my favorite Showtime shows and
also for downloading OS images and software updates.  Using it for these
purposes doesn't harm or degrade my network and is a very appropriate
set of uses for me or any other user on my network.  It does help that I
have optimized the software to use a limited number of connections, and
have also optimized my network to ensure that no customers are able to
open an excessive number of connections to use it.   This not a
violation of "Network Neutrality" or an example of "Intentional
Degradation" to an application.   It is optimization.  It is also the
responsibility of companies like Vuze to make sure that their software
is optimized for good performance as well - it is in their best interest.

Bit Caps are not necessarily the answer, as it introduces levels of
billing complexity and doesn't always represent the best solution.  If
there is extra capacity on the network, and the provider's backbone
connection is not subject to bit caps or usage-based billing, then bit
caps are not needed because the economic cost of extra bits is
inconsequential.   However, too many have taken this too far, leading to
the idea that "bits are free", which is total B.S.   There is always an
underlying foundational cost of infrastructure connectivity, and that
cost needs to be taken into consideration.   The "free bits" exist in
the netherland of non-peak hours and the interval between a backbone
connection that is too large and one that is saturated.  Free bits
represent a place for innovation, and some providers are doing just
that, with open downloads and service level upgrades during off-peak
hours.   But not all bits are free.

In conclusion, I don't think that the Vuze petition is too far off the
mark.   Someone SHOULD be raising a stink about what Comcast is doing -
it goes beyond prudent network management and right into anti-trust type
behavior.

Matt Larsen
vistabeam.com









Anthony Will wrote:
Here is some food for thought,

We may want to approach this issue with a free market approach.  We
may want to emphasize that the free market can and will self regulate
this behavior.  If Comcast is discouraging their customers from
operating this type of software, that creates an opportunity for
another operator to move into the area that does not. We do have to
keep in the back of our mind that the main issue for us as wireless
operators is that P2P solutions create an burden on our systems not so
much for bandwidth but on the amount of connections that are created
by this type of software.  One P2P application that goes wild with
2000+ connctions can bring an AP to its knees thus effecting 50 - 200
other customers on that same AP.
We may also want to empathize that his type of "distributed" content
if allowed to continue likely will lead to bit caps or other types of
metered solutions for customers.  Vuze and other "content" providers
are looking to use our infrastructure to implement their business
plans without paying for that distribution, with the minor exception
of a one time "seeding" of that contact to the Internet.  This is in
my opinion as close to theft as you can get without crossing the
line.  The only recourse that operators will have is to implement a
bit cap (by the way this is common in almost every other part of the
world) in order to fund the increased infrastructure needed to carry
these content providers products for them.  Ultimately the customer is
the one that is going to have to pay for this and other organizations
bypassing of the reasonable cost for the distribution of THEIR content.
Of course we would also want to put in there the reality that the vast
majority of the content provided by P2P is the illegal distribution of
copywrited materials.

Looking forward to the discussion,








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