Today, we sent a letter to the FCC in response to Free Press’ submission objecting to Senator Olympia Snowe’s sensible proposal for a way forward on the FCC’s Notice of Proposed Rulemaking on Preserving the Open Internet.  Rather than an overbroad blanket of Commission action, Snowe’s framework focuses on unjust or unreasonable discrimination that causes consumer harm or is anticompetitive.

The basic problem with Free Press’ approach is that it ignores the fundamental character of the Internet.  Rather than helping consumers, it would instead deprive consumers of their ability to choose how to use Internet bandwidth and services.  How is this pro-consumer?

This issue boils down to whether we want smart broadband networks that recognize the Internet as dynamic, innovative and ever-advancing, capable of enabling the latest gizmos the edge community can offer or whether we want dumb broadband networks that would only be capable of responding to the lowest common “quality” denominator, limiting the quality of those gizmos available to consumers.

At the CES show in Las Vegas last week, it was reported that White House adviser Andrew McLaughlin stated that many of the devices we use every day aren’t “smart” enough, which leads to wasting spectrum capacity and missing out on a better wireless broadband experience.

So, why would we want to link ever-smarter devices to government-mandated dumb networks?

We wouldn’t.

Smart devices need smart networks to access increasingly complex smart applications, not a one-size-fits-all network that slows down innovation and reduces, rather than enhances, a user’s experience.

Senator Snowe’s flexible approach, which was echoed by Google and Verizon Wireless, gained momentum at a recent FCC Workshop, where Paul Misener of Amazon supported the commercial provision of such enhancements by broadband network operators to content and application providers.  During the workshop, Misener said, “It’s always seemed to me that that [Paid QoS] would be appropriate so long as other customers of the network operator are not affected.” So, the reality is more complex than the simple standard Free Press offers.

As an infrastructure provider, we are building a smart IP platform that is capable of handling all types of applications and content irrespective of the demands they place on the network.  We want to innovate by offering products that provide edge providers with whatever capabilities their application, game or content require and that our network can deliver.  The more services that we can sell to support that platform, the greater the reach the network can have for consumers, all leading to a virtuous cycle of investment at all levels of the Internet – edge and core – which depend on each other for their success.

As we wrote earlier, we appreciate Google raising this issue before the Commission, and Senator Snowe deserves praise for her thoughtful framework to address it.   The simple fact is that when network operators invest and innovate to expand the reach, capacity and capabilities of their platforms, they enable investment and innovation at the edge of the network.  A rigid nondiscrimination standard that arbitrarily cuts off business models that are neither anticompetitive nor harmful to consumers is not one designed to promote consumers’ interests.

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