The Privacy Misdirection

Posted by: Bob Quinn on May 27, 2016 at 8:02 am

Today, we will file our official comments in the Commission’s privacy proceeding. The fundamental message will be that the FCC should follow the FTC’s lead and adopt a notice and consent framework for privacy that is entirely consistent with the FTC framework that has governed since the inception of the Internet.  That is contrary to the FCC’s current proposal neatly summarized by FCC Chairman Wheeler at a recent hearing: “For decades, the Commission has steadfastly protected consumers against misuse of their information by [telephone companies] ….  It only makes sense that consumers should enjoy similar privacy protections in the world of broadband.”  The problem with the FCC’s current approach is that it doesn’t reflect the reality of how the internet actually works.

That “misperception” is captured by a wrong-headed conclusion in the NPRM that ISPs are uniquely in a position to develop highly detailed and comprehensive profiles of their customers.  It is just not true.  In a prior blog, I talked about Prof. Peter Swire’s paper commissioned to help educate the FCC on the different data collection capabilities of all the platforms operating in the internet ecosystem.  [Not] surprisingly, that paper was neither cited nor referenced in the NPRM.

So, it shouldn’t be a shock that a recent Future of Privacy Forum blog post explained that the FCC’s proposed rules reflect “a fundamental misunderstanding of the current online advertising ecosystem, which is fully capable of tracking individual behavior across the Internet as well as between devices.” The post visually illustrates how a consumer’s visit to a single website ( actually results in information being shared with, and received from, 24 third party sites. Once these connections are established, these ad networks are then able to track the consumer and link data about that consumer as she/he browses the internet. If the connection is to a party that has personal information about you (e.g., a social media or email platform), that third party can easily append this new web browsing information back to your personal profile of your internet activity. If the connection is made via a mobile device, the unique device advertising id allows the third party to add to or build a similar profile of the internet activity specific to that device.  So, when the Chairman testified that when you make a decision to access Google, WebMD or Facebook that “only one entity collects all of that information,” he was just flat out wrong.

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AT&T Welcomes ITC Report on Trans-Pacific Partnership (TPP) Agreement

Posted by: AT&T Blog Team on May 19, 2016 at 1:53 pm

Yesterday, the U.S. International Trade Commission (ITC), an independent agency, released its report on the Trans-Pacific Partnership (TPP) Agreement. The following statement may be attributed to Tim McKone, AT&T Executive Vice President of Federal Relations:

“We are encouraged by the ITC’s report, which finds that the TPP would help develop cross-border trade in services and would benefit the U.S. economy.

“AT&T supports Congressional approval of TPP. Trade agreements allow countries to compete on a level-playing field by opening up markets and raising global standards. Once adopted, TPP will help establish 21st Century rules for all sectors of the economy, including the digital economy, and will promote U.S. economic growth, job creation and investment.”

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BT Overreach: Stale Data
Yield Rotten Results

Posted by: AT&T Blog Team on March 29, 2016 at 9:41 am

 By Rich Clarke, AT&T Assistant Vice President of Public Policy 

BT Americas (BTA) has repeatedly beseeched the Federal Communications Commission (FCC) to revoke its regulatory flexibility granted to DS1 and DS3 special access – and now argues that all U.S. Ethernet services should be similarly regulated if they are to perform as well as those in Europe. Further, BTA often asserts that the performance of its Openreach subsidiary supplying special access services in the UK is far superior to U.S. performance.  While BTA’s past claims have been repeatedly refuted by AT&T, its recent Reply Comments introduce a new “study” purchased from European telecom consultancy, WIK. This study argues that Ethernet prices are distinctly higher in the U.S. than in Europe, and that this unhappy state is due a lack of competition and competent regulation in the U.S.  A little detective work shows these claims about Ethernet to be as fanciful an overreach as BTA’s prior claims about DS1 and DS3 services.

WIK’s February 2016 report presents two sets of Ethernet price “data.” The first comes from another consultancy, Ovum, and dates from August 2013. WIK uses these Ovum (2013) data to estimate Ethernet prices for the U.S., the UK, France, Germany and the Netherlands.  Based on this comparison, BTA and WIK conclude that Ethernet prices are higher in the U.S., and that Ethernet adoption is lagging in the U.S.

When drawing this conclusion, it is unfortunate that BTA and WIK apparently were unaware that on Sept. 28, 2015 Ovum published an update to its 2013 report. Examination of Ovum’s 2015 report reveals major changes in the Ethernet market over the intervening two years.  In 2013, Ovum reported U.S. prices for 1G metro Ethernet to be $31,060 per year.  Just two years later, this price had dropped by 36% and was $19,879.  Declines in U.S. 10G service prices were even greater – dropping by nearly 58% from $61,237 in 2013 to $25,873 in 2015.  But even more telling, Ovum’s 2015 report projects that by the 2018-20 period, U.S. prices for 1G and 10G Ethernet service will be no higher (and sometimes significantly cheaper) than the prices from the four European champions that WIK selects as comparators to the entire U.S.  Further, over the 2015-20 time period, Ovum (2015) projects that U.S. metro Ethernet lines will grow at a compounded annual rate of 16.9%, while the four-country European growth rate will be only 9.2%.  The moral here, if you rely on stale data, expect rotten results.

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Something Amiss in Washington

Posted by: AT&T Blog Team on March 24, 2016 at 9:38 am

By Len Cali, AT&T Senior Vice President of Global Public Policy

Last week, I had the privilege of participating in the Digital Economy: Chances and Challenges conference in Prague. The Czech national regulatory authority, Česky telekomunikační úrad (“CTU”), under the leadership of Chairman Jaromir Novak, organized the conference jointly with ICANN.

The gathering offered me an opportunity to share AT&T’s view on innovation and regulation. Even more importantly, it allowed me to learn firsthand what policymakers and industry stakeholders are doing and thinking in eastern Europe. It should be no surprise that in this vibrant and technically sophisticated region of the world, much is underway with respect to smart cities, the transition to next generation networks, and extending broadband to all citizens.

Nonetheless, I was surprised to learn that Croatia has already completed the transition to an all-IP network and shut down its legacy PSTN central offices.  I was also impressed by the cutting edge work being done in Slovenia around innovative fixed wireless broadband technologies and services.  Most encouraging of all, I found many policymakers looking forward, aiming to safeguard consumer interests and address the challenges of the 21st century without looking backward or trying to pick winners and losers in the marketplace.

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AT&T Statement on Release of Trans-Pacific Partnership (TPP) Text

Posted by: AT&T Blog Team on November 6, 2015 at 4:00 pm

The following statement may be attributed to Jim Cicconi, AT&T Senior Executive Vice President, External and Legislative Affairs:

TPP brings higher standards and protections to countries that represent nearly 40 percent of the global economy.  It will open markets and establish rules of the road for a 21st Century digital economy.  The e-Commerce commitments in TPP also provide a benchmark for reference in future trade agreements. We commend the Office of the United States Trade Representative for their tireless efforts, and hope Congress will work to ratify this agreement as soon as possible.”

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