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Net Neutrality

FCC Notice of Inquiry

NOI FCC-07-31A1.

The U.S. Federal Communications Commission has opened an inquiry on the net neutrality issue. We believe that this is an important issue and have provided our comments to the commission.

We have found the discussion about the so called “net neutrality” has lacked rigor and has not focused on the key issues. These comments attempt to correct these problems and to extend the discussion to areas that the Commission should address to insure consumers are provided choice and that competition is fostered on an equal basis.

The nature of services offered over broadband networks is fundamentally changing. Broadband networks such as the FiOS network provided by Verizon and the U-verse network provided by AT&T provide services in addition to and independent of the Internet services. Both AT&T and Verizon offer TelcoTV services over these new networks, in particular. This means that the broadband service should be considered independently of the Internet service since Internet access is only one component of a broadband service.

It appears that the cable companies may be moving in the same direction as they introduce 100 Mbps DOCSIS 3.0 based data services. At least some of them are considering offering TV services over this broadband connection using IPTV technologies. It is likely that this will lead to a partitioned broadband service similar to the new telco broadband services.

One of the questions in this inquiry is whether or not all packets on an Internet service should receive equal treatment. We believe that the answer to this is no, that there should be service differentiation that gives the packets for some services higher priority over other services. However, this must be done in a way that provides fairly priced equal access to all service providers and does not discriminate against one or the other. In particular, this approach should not enable the broadband service provider to offer a better level of service and relegate its competitors to a lower level of service.

We also believe that there are now new opportunities for stimulating service competition by extending the principle of equal access that was developed as part of the AT&T divestiture in 1984 to broadband services. Basically, service providers should be able offer services over any broadband network on an equal basis with each other and with the broadband service provider itself. This would apply to the Internet service, to the TelcoTV service, and to any other service offered over a broadband network.

Differentiated services can be added to these services that permit VoIP telephony and gaming services to offer preferential services that improve the experience of their users. These services should be offered on an equal basis to all companies and should not be part of exclusive agreements between the broadband operator and a few others or used only by the broadband carrier itself. This means that Vonage, Packet8, and Verizon should be able to provide priority treatment for their VoIP services delivered over AT&T’s broadband network and that AT&T should not be able to provide this preferential service only for its own VoIP service.

TelecomView also believes that the TelcoTV services that the broadband service providers offer today should be opened up on an equal access basis. It should be possible for Akimbo or MovieLink to offer a supplementary video on demand service through AT&T’s U-verse or Verizon’s FiOS TV service though an open interface and with a fair set of access charges. It should also be possible for a video service provider to offer an alternative video offering to the AT&T U-verse or the Verizon FiOS TV offering, again through an open interface and with a fair set of access charges.

TelecomView is making the following specific recommendations to the FCC:

· Best efforts Internet services should be treated equally by broadband service providers. There should no discrimination between best efforts data services between Internet service provider or between the broadband operators own Internet service and other Internet service providers.

· Prioritization and preferential treatment should be permitted and even encouraged on a service basis to improve the quality of VoIP, gaming, and other services that require a higher level of packet delivery performance. This prioritization should be provided in ways that do not substantially reduce the quality of traditional best efforts Internet services such as email, web browsing, or file transfer.

· Access to all of the broadband services such as TelcoTV services that broadband operators offer. This access should be provided on an open basis and at a fair price.

You may order a free copy of TelecomView's submission in the Order White Papers section.