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oh LOOK

@videotron.ca

Bells NEW July 11th CRTC Submission

Full article and full Bell CRTC submission found at:

»www.p2pnet.net/story/16364

“In accordance with the Commission staff letter of 19 June 2008 and Bell Canada’s (or the Company’s) letter of 9 July 2008, the Company is hereby filing its Answer to the CAIP (Canadian Association of Internet Providers) Application dated 3 April 2008.”

That’s Bell Canada’s Mirko Mr 5% Bibic to Canadian Radio-Television and Telecommunications Commission secretary general Robert A. Morin.

Bell admits it’s, “also in receipt” of 25 comments from such as Google and Per Vices, the company which also provided a way for people to get around Bell’s bandwidth throttling “traffic management” actions. The complete list is in the document below.

Dear Mr Morin, it says >>>

Subject: Application requesting certain orders directing Bell Canada to cease and desist from “throttling” its wholesale ADSL Access Services

In accordance with the Commission staff letter of 19 June 2008 and Bell Canada’s (or the Company’s) letter of 9 July 2008, the Company is hereby filing its Answer to the CAIP Application dated 3 April 2008.

Sent in yesterday, it’s a day late —- Bell asked for, and was granted, an extension —- and considerably more than the dollar short. With a little luck, we’ll be able to give you CAIP’s respoinse on Monday or Tuesday.

But here it is in full, including an interesting dissertation on deep packet inspection (DPI).

Continues at: »www.p2pnet.net/story/16364


getreal

@teksavvy.com

How full of shit can they be? and how stupid do they expect everyone to be?

"Bell respects the privacy of its customers

ES17 The Company’s use of DPI technology as part of its traffic management practices is such that the actual contents of the communication exchange are not examined. Rather, only the protocol headers are examined and the DPI equipment does not retain the information reviewed in the packet headers."

Seriously? You buy this?


mazhurg
Premium
join:2004-05-02
Portage La Prairie, MB
·MTS
·TekSavvy Solutions..


4 edits
reply to oh LOOK
Meaty reply.

Again, they seem to like to try to confuse GAS and internet services.

Ha yes, "nobody else has it right. Only we know the answers and you must trust us to tell it as it is as we are not about to show why they are wrong. They must prove the negative; not us."

Oh oh, here's cable in the corner. It passes more houses than DSL so it's a usable option! -- What do you mean, no access to remotes? We will connect orders to them, honest if there is anything left after we plug our own sympatico folks

We only look at the applications headers.. honest! (wonder if anyone tried to make a spoofed IE header on port 80 on a P2P stream)...

Lots more in there. Rehashing the same old excuses, and easy to pick apart. Perhaps Bell thinks that by putting out a massive DSL dazzle they may bemuse the readers?

bah!


emerald_b

join:2008-04-07
North York, ON

reply to oh LOOK
My personal favorite part was that throttling promotes innovation instead of hindering it... LMAO Basically... cause we don't have p2p we will come up with new things. These documents are so full of it... just like every other document that bell has put forth to date. I couldnt even read through the whole thing.


Candoo3

join:2005-01-24
reply to oh LOOK
How would they get it, when it's not posted on the CRTC site yet?


Guspaz
Guspaz
Premium,MVM
join:2001-11-05
Montreal, QC
·Colbanet
·TekSavvy Solutions..

reply to oh LOOK
My favourite bit of bullshit:

quote:
It is called “Deep Packet Inspection” because it looks beyond the routing and transport headers, deeper into the application packet headers, to determine the type of application that is communicating, but not the content itself (see figure below).
That's nice, except APPLICATION HEADERS ARE PART OF THE CONTENT ITSELF. As in, they are the payload of the TCP packet. You need to look at the CONTENT to get the application headers.

ragingwolf

join:2003-04-22
Nepean, ON

reply to oh LOOK
Ya that document is full of BS, they even reference rogers a bunch of times, when cable and dsl are completely different technologies.

The way they conveniently leave out the physical layer to the network is ridiculous. What happened to the pppoe layer bell? Do they honestly think people are dumb enough to think that an entire connection can't be throttled?

And figure 4 makes me want to laugh. Using an isp like teksavvy, at no point in bell's network are data packets in the form of tcp streams, which makes this representation completely, utterly false.


milnoc

join:2001-03-05
H2Z
·TekSavvy Solutions..

reply to Candoo3
When you send a submission to the CRTC, you must also email a copy of the submission to the primary interested parties. One of those parties received Bell's Cc and handed it to the media, which is no problem if it's a document intended for public disclosure.


emerald_b

join:2008-04-07
North York, ON
reply to oh LOOK
lets go with pitchforks and torches to bells head office :P and point out the error of their ways LMAO


Candoo3

join:2005-01-24
reply to milnoc
With CAIP's last submission, I know Rocky wouldn't say anything until it actually appeared on the CRTC site. That's why I was trying to figure this one.


Stewy
Premium
join:2007-12-12
Kitchener, ON
"The incorrect premises lead to invalid calculations and comparisons, which only serves to confuse the relevant issues."

I've read about 1/4 of it and I can't believe what I'm reading.


pnjunction
Teksavvy Premium
Premium
join:2008-01-24
Toronto, ON
·TekSavvy Solutions..

reply to ragingwolf
said by ragingwolf See Profile :

What happened to the pppoe layer bell?
No kidding. I didn't read it but looked at the figures. They show the IP, TCP, application and data layers but negelct to mention that they're ALL inside PPPoE packets they they're supposed to deliver unmolested to their customers/competition.

The fact that I didn't know whether to refer to 3rd-party ISPs as customers or competition is really the underlying issue here. Until this conflict of interest is rectified, Bell is going to do whatever they can to screw us over (no ADSL2, no access to RDSLAMs, and so on).


Maynard G Krebs

@teksavvy.com

reply to oh LOOK
A few quick observations

In a quick glance - I have not read it with a fine-tooth comb yet, a few things jump out at me:

1) In section ES6(i)(b) they say, "During this proceeding parties have continuously oversimplified the work required to address network congestion. In paragraphs 98 to 101, the Company notes several inconsistencies and faulty assumptions in an article1 presented by CISP to support its claims. In the article, Mr. David Burnstein, a DSL industry analyst, ignored some very important costs. Contrary to his assertions, simply upgrading DSLAM ports to GigE is not all that is required. This may explain how the author formulated the incorrect conclusion that Bell Canada’s congestion is minimal and easily solved."

2) In section ES23 they say, "GAS customers generally, including the Applicants, have used and continue to use unsubstantiated allegations regarding the facts to then jump to inappropriate conclusions. The Company understands the Commission’s need to examine the detail of this congestion in order to satisfy itself that there is no unjust discrimination or anti-competitive motive underlying the Company’s actions."

*** The answer to both 1) and 2) above is as follows:

a) Restore, by CRTC order, the status quo existing on September 1, 2007 for all CAIP circuits and Sympatico users.

b) Using independent network specialists with obsevers from the CRTC, Bell, and CAIP present, monitor BAS traffic from both Sympatico and CAIP customer for bandwidth consumed, error rates, congestion, etc... for a period of 1 month.

c)Then change the DSLAM aggregation links to GigE and repeat step b) for another month.

d) Execute other tests as required to build a complete profile of network steady-state conditions and to identify any problem areas and test prospective solution.

e) Publish all findings publicly.

f) Then let Bell make formal submissions to the CRTC for any changes, such submission subject to comment by interested parties.

3) In Section 4.1 (17), they say, "At least one party(10) to this proceeding believed that Sympatico retail Internet and GAS services are offered over separate and distinct networks or at least are isolated from one another. This is not the case. The GAS service offered to wholesale ISPs and the retail Sympatico Internet access service offered by Bell Canada share and have always shared the same access network and therefore will experience the same benefits and the same problems. As discussed in the Interim Answer, wholesale traffic from all of the ISPs who use GAS and Bell Canada’s retail Internet traffic traverse the same central office facilities, the same access network and part of the same backbone network. Figure 1 illustrates how GAS and Bell Sympatico retail traffic transit through the same path/equipment from the DSLAM up to the BAS (and the associated DPI), the point in the network where retail and wholesale traffic is aggregated. The GAS and retail traffic also transits through some of the same backbone network links since the wholesale traffic must be sent to the wholesale equipment/facilities before going to the Internet. It is in fact impossible to distinguish traffic from a retail Sympatico end-user from the traffic of a GAS end-user until the two services reach the BAS."

***With respect to Bell's section 4.1 (17) statement, if ISP and Sympatico traffic has ALWAYS been aggregated as Bell claims, how come no DPI/throttle was present on GAS capacity leased by CAIP members between the date Bell first began throttling Sympatico users in 2007 and the end of March 2008 when Bell began to throttle/DPI CAIP traffic? No discernible impairment to CAIP traffic was present prior to March.

This just goes to show Bell's utter contempt for the CRTC and Bell's customers (CAIP), and to the intelligence of Canadians in Quebec and Ontario.

Nothing short of restoring the network to pre-September 2007 status and then having independent scientific-method studies (ie. change one variable at a time and measure its effect) done by independent experts acceptable to all parties in this proceeding, is required to get to the bottom of the quagmire Bell has created. Then, and only then, can the veracity of ANY of Bell's claims to the CRTC be judged.

Until then all Bell's statements can only be viewed as unsubstantiated BS.

--------------------------

One other thing - Bell claims that they can still say "up to 5Mbps" in their sales pitches because on days when it is exactly 13h 16m 27.37s after new moon, somebody, someplace on their network might get 5Mbps throughput if they live right next door to a CO with brand-new copper to the CO.

What the CRTC should be ordering all Common Carriers & ISP's to advertise is a typical Mbps figure (up/down) in the following way (or something close to this):

Residential ADSL Customers (no FTTN)

8am-5pm 5pm-12am 12am-8am
Weekdays 3300/580 30/1DTx 30/1DTx
Weekends 30/1DTx 30/1DTx 30/1DTx
for the period 2008/01/01 - 2008/03/31

Residential ADSL/2+ Customers (FTTN)

8am-5pm 5pm-12am 12am-8am
Weekdays 7300/980 30/1DTx 30/1DTx
Weekends 30/1DTx 30/1DTx 30/1DTx
for the period 2008/01/01 - 2008/03/31

where
DT == DPI spying & Traffic Throttled
x = C (common carrier) or I (ISP) - to identify who is responsible for the spying/throttle

and if ANY DPI/Throttle occurs during any period then that period MUST also bear the DTx designation.

Something similar for should also be done for business customers.

All data must be recomputed quarterly and used in advertising/all claims of performance no later than the 15th of the month following for the next quarter.

Claims of data rates must reflect the technology used, weighted average distances to CO's of all customers, and any other factors like FTTN or not, cable or xDSL.

Only then can there be any intelligent decisions made by customers about the relative merits of one form of service vs. another.


Maynard G Krebs

@teksavvy.com
Sorry about the loss of formatting on the tabular data.

Data rates used in the examples are down/up, not up/down as originally stated.


drjp81

join:2006-01-09
canada
·TELUS
·TekSavvy Solutions..


1 edit
reply to oh LOOK
Re: Bells NEW July 11th CRTC Submission

Holey Mackeral,

So far I've been pretty silent, because I find I am in no way an expert (though interested) on these matters. But when a layman like me can spot questionable stuff like this in their answers, its downright scares me.

Original Bell Answer:

ES2 ....data pulled from extensive studies on the growth of Internet demand, network capacity and congestion, as well as the Company’s more than a decade of experience ...

Studies paid for by your's truly ma Bell of course. And was there ever any doubt the net would grow? So grow with it!

ES19 Bell’s DPI traffic shaping activity does not “control the content or influence the meaning or purpose of telecommunications” ...

If that is so, why don't you limit ALL BANDWITH HUNGRY APPLICATIONS TO "MANAGEABLE LEVELS", like streaming video too?

Argh. They areally burn me up.
--
Cheers!

DSL_Ricer
Premium
join:2007-07-22

reply to oh LOOK
I found this section fairly bad:

ES21 Several parties have claimed that traffic management will hinder innovation. The Commission should see these [as BS]. [N]ecessity is the mother of invention. Without any regard to network capacity, P2P file sharing application designers could develop applications designed to use all of the bandwidth that is available. It is no coincidence that P4P is emerging as a possible solution with regards to P2P file sharing at a time when ISPs around the world are starting to implement traffic shaping measures.[...]
Except that P4P is a framework to reduce Internet traffic usage. This technology can't and will never substantially decrease the load from ISPs to end users, the segment bell is throttling. This is because the only existing (logical) link in between the the user and network content goes to the ISPs end-user gateways. The data MUST travel over this link. There, therefor, can't be a reduction in load on this link.


Candoo3

join:2005-01-24
reply to oh LOOK
This IS the last response that Bell has the opportunity to make before arbitration, yes?

CAIP et al really need to tear this apart.


jfmezei
Premium
join:2007-01-03
Beaconsfield, QC
·ELECTRONICBOX

this is long, comments just for the executive summary....

will hope to avoid duplication of arguments in what follows.

text between ## denotes quotes from Bell's letter.

----------------------------------

Since the letter was posted on the p2pnet.net web site, it is now public document. (even of not on the CRTC web site yet) I assume someone within your group got a copy and sent it to the p2pnet folks)

Some comments:

##
a. Since 2001, the Company has invested over $3 billion in capital investments on its high-speed Internet service.
##
In an interview on CBC's Spark (.MP/ available on the spark web site), Bibic mention the "3 billion invested", but was asked "was that all on the internet" and he had to say "hundreds of millions on internet".

Not sure if this is all for the same timeframe as the current Bell document. Something to check.

-----

As Bell upgrades links to ethernet, it should be able to use legacy ATM equipment freed on those links to tempoeraily upgrade remaining ATM links, so the argument of continued purchase of expensive ATM equipment shows bad management on Bell's part. If it is cheaper to upgrade to ethernet, the Bell should simply be accelerating upgrades to ethernet.

And Bell has not demonstrated in its statistics whether congestion occurs only at ATM links or both ATM and ethernet. If congestion is only at ATM links, this should be viewed as a temporary problem to be solved by accelerated upgrade programme.

--------------

##
a. The Company initiated the transition to usage-based billing in December 2006 when it ceased offering its “unlimited traffic” plan to any new subscribers. However, the transition to usage-based pricing cannot be the sole solution to network congestion, nor is it an instant "fix" for three principal reasons:
##

We are talking about GAS/5410 CRTC regulated tariff, and not about Sympatico's retail pricing. GAS$5410 is NOT usage based and there has not been any process initiated by Bell to change that tariff.

Usage based pricing is easily accomplished with normal existing routers, and thus do not need DPI equipment. Independant ISPs already accomplish this with their routers and Bell does not need to put any equipment between them and their customers to do that job.

-----------------------------

i. terminating or managing the service of users who consistently breach the Company's Acceptable Use Policy; and

Bell Canada has no right to decide to terminate customers of its competitors. This is not a submission about Sympatico, it is a submission about GAS/5410.

------------------------------------
##
The Company does not block any form of P2P file sharing applications nor does it shape non P2P file sharing applications.
##

The speed at which Bell cripples certain communicatiosn makes them unusable during the hours where they are crippled and thuse this is similar to blocking them even if technically they still run.

Putting a 5km/h speed limit on the 401 in Toronto between 16:30 and 02:00 would not close it, but would make it ususable and force people to use other routes.

MORE IMPORTANTLY: SINCE BELL REFUSES TO DEFINE EXACTLY WHAT IT DOES THROTTLE' PEOPLE CAN'T KNOW WHAT WILL AND WILL NOT BE THOTTLES AND SERVICE PROVIDERS CANNOT ADJUST THEIR SERVICE OFFERING TO REFLECT THIS SERVICE DEGRADATION.

EVEN MORE IMPORTANTLY: SINCE BELL RESERVES THE RIGHT TO CHANGE ITS CONFIGS ANYIME IT WANTS WITHOUT WARNING ANYONE: SERVICE PRODIDERS ARE IN EVEN WORSE SITUATION SINCE THEIR SERVICE OFFERING CAN BE CHANGED BY BELL WITHOUT WARNING. THIS IS A **VERY** VISIBLE CHANGE THAT MATERIALLY EFFECTS END USERS AND ISPs.

----------------------------------------

##
i) P2P file sharing traffic is designed to open several sessions in an effort to transfer data as fast as possible, thus overwhelming other forms of traffic.
##

FALSE. A single PPPoE session exists between end users and their service providers and the number or IP/TCP/UDP links is totally irrelevant to Bell in the GAS/AHSSPI service since Bell only sees PPPoE packets.

------------------------------------------------

##
ii) Because of the possibility of queuing file requests, P2P file sharing can sustain a continuous maximum network traffic load, 24 hours a day, 7 days a week and 365 days a year, as long as there are queued requests.
##

Solved by monthly download limits which many ISPs have had for many years. And for those who still provide unlimited, then they simply need to buy sufficient bandwdith from bell to support those activities.

---------------------------------------------------

##
iii) Some P2P file sharing applications look for the fastest node available, and thus any increase in capacity to one network node will attract increased P2P file sharing upload requests from other P2P file sharing applications resident on other networks.
##

BitTorrent/P2P cannot exceed the speeds of the ADSL links. They cannot abuse those links. They operate at whatever speed the link is, just as any other bandwidth intensive application including the Bell Video store.

And from GAS' point of view, it only manages a single PPPoE session between the user and the ISP. Whatever *internet* networks may be used beyond the ISP is totally irrelevant to the GAS service.

(remind CRTC that this is about GAS/5410 and not Sympatico service)

Remind CRTC that ADSL is not like Cable (re: Roger's comments). ADSL provides *DEDICATED* bandwidth (leased lines) on the "last mile" and full use of the 800kbps give on ADSL lines does not impact neighbours, contrary to Cable. and 800kbps is very small speed for upload and shouldn't be a problem for Bell to handle in its backbone.

-----------------------------------------------------------

##
ES8. As P2P file sharing applications are designed to use all of the bandwidth that is available, additional capacity cannot, on its own, resolve this issue.
##

The ADSL last mile speed is the real bottle neck. No application can exceed that speed. It is a given that increasing the ADSL speed will increase the load on the backbone, but this happens with any application whereher it be viewing you tube, downloading from Bell Video Store etc.

ALL applications will use maximum speed of the slowest portion of a network (aka: the ADSL link).

-------------------------------------------------------------

##
Because P2P file sharing applications are non time-sensitive, these can be "slowed down" during peak hours of traffic without interrupting service
##

Who decided they were not time sesnitive ? And why is the Bell Video Store considered time sensitive and given full access to the ADSL line while BitTOrrent isn't ?

---------------------------------------------------------------

##
"…allow them to suspend or terminate service where a customer uses or permits others to use services so as to prevent fair and proportionate use by others."
##

In this case, since the GAS customer is an ISP, Bell is refereing to suspending an ISP and not an ISP's customers. In the case of GAS, the end users are not Bell Customers. (remind CRTC again that we are not talking about Sympatico)

Another point of view on this issue: What happens if Bell Canada mismanages a service such that fair use by customers negatively impacts other customers ? Would Bell then be allowed to terminate those customers who, despite having made fair use of facilities, have cause's Bell's mismanaged network to be congested ?

AKA: just because Bell delayed upgrade of its legacy ATM stuff doesn't mean that customers are to be blamed for any small congestion issues.

----------------------------------------------------------------

re: QoS issue with Cybersurf/Shaw:

Again, check with your expert Mr Gabe, but this would normally be implemented in the customer premise equipment which would priorituze which packets go over the link first. The involvment of the ISP or carrier would be less important. (and in the case of Bell, since this is a PPPoE service, there is no concept of prioriity of packets since this is to be a transparent Point to Point service, not a managed IP network.

----------------------------------------------------------------

##
248. The Commission considers it appropriate that each cable carrier be provided the ability to manage the potential negative outcome of high-consuming bandwidth end-users in a manner that does not degrade the Q of S to all end-users, whether it is the cable carrier's end-user or the competitor's end-user. The Commission considers, however, that regardless of
##

Cable is a shared medium on the coax compared to the dedicated links on ADSL for the last mile. And here the use of "Q of S" refers to a generic quality of the service, as opposed to the technical QoS packet prioritisation capabilities at the IP level.

-----------------------------------------------------------------

##
GAS service is not offered over a separate and distinct network. The GAS service offered to wholesale ISPs and the retail Sympatico Internet service offered by the Company share and have always shared the same access network and therefore will experience the same benefits and the same problems
##

While the business relationship between Sympatico and Bell is unknown, it si known that independant ISPS, through GAS/AHSSPI fully pay for the bandwidth that their customers use and as such Bell must be made to provide it.

Secondly, Bell's own graphics in its first intervention in April clearly showed AHSSPI as a separate snetwork from that used by Sympatico.

The fact that Bell underprivisioned the DSLAMBAS links because it underestimated average use is Bell's problem and Bell should be made to solve it by providing adequate bandwidth on those links.

Secondly, if GAS customers were given equal treatment to Sympatico, how come Bell doesn't raise ADSL profiles for GAS end users to 7mbps and give them equal access to remote ADSL ports ?

And what if GAS customer end up paying more per end user and end up buying more bandwidth for aggregation than Sympatico ? Shouldn't they get better service than Sympatico ?

------------------------------------------------------------

##
ES14. Finally, there is no ulterior motive attached to the Company's management of network congestion; it was not launched in order to i) launch usage-based billing,
##

Contradiction with their May 15th filing where they stated the exact opposite. And Bell even mentions in this very docunment they want to use DPI for usage based billing.

----------------------------------------------------------

##
ES15. Despite the many claims by CAIP and other parties, the evidence clearly demonstrates that there is no ulterior motive or any basis for a claim of unjust discrimination.
##

The evidence clearly shows that Bell is not being honest, is refusing to divulge the exact nature of what it thorttles and how it does it, so Bell is in no position to claim that speculation about its true intentions are unwarranted.

This is especially true since Bell has categorically stated that it feels no obligation to inform GAS customers of any changes it makes to its DPI equipment.

------------------------------------------------------------

##
If there is, indeed, any gatekeeping activity on the Internet, which is questionable, the gatekeeping is being performed by the Internet search engines, which are typically the users’ “window” to the near-infinite content available worldwide.
##

Google doesn't prevent anyone from starting a competing search engine with new features which could eventually overthow Google. Google's arguments are about the need to NOT prevent any new application from emerging.

-Google is not a network, it is an application/service provider. -Bell Canada is a network.
-We can use any search engine. We have no choice for ADSL.
-Bell is in no position to decide what apps we can and cannot use.

----------------------------------------------------------------

##

First, the Notification Requirements do not apply to GAS service (as it is not a bottleneck service); second, traffic management is not a notifiable change because it does not require ISPs to make adjustments in their network.
##

"Not a bottleneck service". Interesting terminology. Could this mean that if it is not a bottleneck service, Bell has no right to treat it as such by managing packets to prevent bottlenecks ?

Secondly, ISPs must be able to fully define to their customer what service they provide. If Bell blocks certain applications (making them so slow as to be unusable is equal to blocking them), then this is definitely impacting ISPs and theur customers and ISPs need to be aware of the full details of the throttling in order to have an honest description of what service they can and cannot offer.

--------------------------------------------------------------------

##
ES17. The Company's use of DPI technology as part of its traffic management practices is such that the actual contents of the communication exchange are not examined. Rather, only the protocol headers are examined and the DPI equipment does not retain the information reviewed in the packet headers.
##

My submission has proven this to be wrong. From a network popint of view, anything in tye packet payload is to be considered user data, even control bytes used by an application.

A PPPoE network has no business knowing whether a packet transports email, BitTorrent, raw UDP, DNS requests or web traffic.

------------------------------------------------
##
- use any personal identification information of an individual user;
- store or log any personally identifiable information;
- have specific knowledge of a user's real identity;
##

If Bell wants to use this for usage based accounting, collection of this data would be required in order to be able to send usage data to the billing system.

- have knowledge of a user's content;
- have knowledge of a user's URL browsing history;
- have knowledge of a user's Internet search activity;

By definition, DPI equipment looks at this. And the DPI equipment capabilities list prominently the ability to turn on a feature that will capture browsing history and associate it on a per user basis, as well as provide user-specific throttling profiles.

Since serach activity is transmistted as part of HTTP requests, then collecting URL browsing history implicitely includes search requests.

-------------------------
##
- capture and playback any communications exchange; or
##

The Ellacoya equipment is capable of doing this. As per CAELA requirements.

---------------------------------------------------

##
First, slowing the delivery of content does not amount to "controlling" it.
##

Deciding whether a packet should be transmitted to destination or discartded based on what application it is associated with is defrinitely controlling it.

ANALOGY: Bell is dictating what subjects one can discuss on a telephone conversation. Implementing it requires Bell listen to phone conversations to ensure we only speak of subjects Bell has approved.

-------------------------------------------------------

##
Bell cannot influence the meaning or purpose of the telecommunications because Bell has no knowledge of the content itself.
##

Knowledge of what application is being use explicitely requires knowledge of the content. I have proven that Bell must look beyond the PPPoE, IP and TCP headers to decided which packets are associated with an application.

Analogy: If Bell listens for a female "Oh My God" on a telephone conversation to decided whether to "Throttle" that conversation or not, Bell may claim that "Oh My God" may not contain personal information such as birth date, social insurance number etc, but this is still part of a personal and private conversation and Bell legally requires a warrant to listen to any part of this conversation.

------------------------------------------------------------

##
Unwarranted policymaking and/or regulatory measures could hurt innovation, impede competition and decrease the efficiency of Canadian telecommunications
##

Allowing a monopoly to unilaterally decide what regulatiosn it should implement, what packets it should let through and which it should cripple is abuse of power. GAS/5410 is regulated by CRTC to prevent abuse of power.

--------------------------------------------------------------

##
The Company is confident, however, that competition and market forces will encourage, as it has already done, the development of new, better and fairer P2P file sharing applications.
##

Any application designed to avoid being throttled will end up making use of available bandwidth and Bell can then unilaterally decide to throttle it without telling anyone since it has stated it doesn't need to tell anyone about its throttling.

-------------------------------------------------------------

##
Until that time, the Company has endeavoured to limit its traffic shaping
##

Limit to what ? Since Bell won't fully define exactly what it is crippling, the use of the word "limit" is wrong since those limits are not defined, and Bell reserves the right to change those limits without warning.

Secondly, crippling traffic down to below 30KB/s is not traffic shaping, it is crippling of applications at a speed so slow that it makes them ususable for 9.5 hours per day.

--------------------------------------------------------------

##
Outside of that one concern, the Company submits it is not for the regulator to second guess the Company's engineering decisions.
##

DPI is not a network management solution, it is a service management solution which defines what types of uses of internet are to be allowed and what parts are not allowed. This is not an "engineering" decision, it is a management decision.

If congestion were a problem, Bell Canada would have delayed Sympatico 40% speed increases from 5 to 7mbps until the backbone was able to support it. That would have been an engineering solution to manage the network. The ADSL speed is the only variable that Bell can control under GAS tariffs. ISPs control how much AHSSPI capacity they purchase to support the type of uses their customers make at the speeds Bell as decided to supply on the ADSL loops.

Management at the application level is not network management, it is service management.

-------------------------------------------------------------------
-----------------------------------------


The Flash
You don't win friends with salad
Premium
join:2002-10-17
Toronto, ON
Nice breakdown, must have worked out a sweat to take all that BS.

Robrr

join:2008-04-19
Toronto, ON
·TekSavvy Solutions..
·Rogers Hi-Speed


2 edits
reply to Guspaz
said by Guspaz See Profile :

My favourite bit of bullshit:

quote:
It is called “Deep Packet Inspection” because it looks beyond the routing and transport headers, deeper into the application packet headers, to determine the type of application that is communicating, but not the content itself (see figure below).
That's nice, except APPLICATION HEADERS ARE PART OF THE CONTENT ITSELF. As in, they are the payload of the TCP packet. You need to look at the CONTENT to get the application headers.
This document better be legit because this alone is the smoking gun that will give CAIP, CIPPIC, the Privacy Commissioner, the CRTC and probably a LOT of other people more than enough ammo to destroy Bell in its FULL ENTIRETY.

That single statement is more than enough cause the complete removal of that equipement.

Once again if this document is legit CAIP should seriously push to for the IMMEDIATE CEASE AND DESIST of the throttling. This is the exact same as the post office reading your mail.
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