This past Friday, Digital Society submitted three separate comments for the FCC’s Comments Period session on its Network Neutrality NPRM.  These comments can be found through the FCC’s filing system and are open to the public.  But in the interest of full transparency and ease of finding them we wanted to also post them here.

Click to view the .pdf in a pop up .pdf reader or Right-Click, Save As… to download a copy for your files.

Digital Society FCC NPRM Comments: Summary
A summary of various positions Digital Society has taken on the issue of Net Neutrality regulation over the past months leading up to the FCC NPRM and Comments Period.

Digital Society FCC NPRM Comments: Preserving the Open and Competitive Bandwidth Market
Something unfortunate happened in the search for Net Neutrality and an “open Internet”. We have essentially been asked to suspend economic reason and accept the premise that the commodity of Internet server bandwidth is not a free market but a low-cost fixed rate service. We are told by proponents of Net Neutrality that the Internet is a place where the smallest websites that might pay tens of dollars per month for Internet connectivity have the same capability as the largest websites that pay millions per month for Internet connectivity. “Equal access for equal payment” has been replaced with “equal access for any payment”. By trying to “preserve” a vision of the Internet that never even existed, Net Neutrality would eliminate the existing open and competitive Internet server bandwidth market.

Digital Society FCC NPRM Comments: Net Neutrality Economic Study Based on Flawed Analysis
Inimai M. Chettiar and J. Scott Holladay from the Institute for Policy Integrity of the New York University School of Law has published the paper “Free to Invest: The Economic Benefits of Preserving Net Neutrality1” (henceforth referred to as “Free to Invest” in this article for expediency). Free to Invest argues that Net Neutrality is crucial to the economic health of the Internet and that without it; broadband providers would be free to extort content providers by double charging for network access. But the analysis is based almost exclusively on a misguided and flawed understanding of how the modern Internet actually works.