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ZappaF

@above.net

Read the Letter Folks

The prof's raise a very specific critique:

1) The proposed rule defines "nondiscriminatory" in a very narrow way, where only payment for prioritization would be banned. In other words, it would be perfectly acceptable for Comcast to prioritize Fancast traffic over YouTube traffic.

2) The FCC gutted the standard for "reasonable network management" established in the Comcast case. There, the RNM standard had to be narrowly tailored to serve a critically important interest. In the proposed rule, the FCC just rejected this standard, and replaced it with nothing. In other words, it would be perfectly acceptable under this standard for Comcast to forge RST packets to "delay" P2P, all in the name of fighting congestion.

These are specific critiques. The letter indicates the profs understand the rule must be flexible, but they are trying to get the FCC to close loopholes, or indicate that they did or did not intend for these loopholes to be in the proposal in the first place.

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