Media Access project, as counsel to the Benton Foundation, Center for Media Justice,
Consumers Union, New America Foundation, and Public Knowledge (collectively “Public
Interest Commenters” or “PIC”), respectfully submits these comments in response to the Public
Notice: “Further Inquiry Into Two Under-Developed Issues in Open Internet Proceeding.”
Public Interest Commenters respectfully suggest that the two issues set forth for comment in the Public Notice—the treatment of “specialized services” and the application of Open Internet rules to mobile wireless platforms—are not “under-developed,” as these questions already have been raised and discussed in this proceeding. Nevertheless, Public Interest Commenters welcome this opportunity to
recount briefly their prior positions, explaining herein that specialized services must be a limited
category (if recognized by the Commission at all) and that mobile wireless broadband networks
must be protected by Open Internet rules.
The Commission should not make any determinations with regard to specialized services in this proceeding; but if it does, should adopt the guidelines set forth herein for preventing an ill-defined category specialized services from becoming an exception that swallows Open Internet rules. The Commission also should apply Open Internet rules to wired and wireless networks, recognizing that the same openness principles can and should apply to broadband Internet access services no matter the technology used to offer them. The Commission therefore should make clear that transparency rules apply to mobile broadband networks, and that users have the right to use non-harmful and applications on such networks.
You can download the full comment on the right.