Net Neutrality & VoIP Carriers ECG.CO, NOT A LAW FIRM
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1 Net Neutrality & VoIP Carriers MARK R LINDSEY, NOT A LAWYER ECG.CO, NOT A LAW FIRM
2 Background 2005: ISP AT&T announces preference for sender pays, & special fees for more for preferential treatment of their traffic. 2007: ISP Comcast modifying or blocking Internet Data to/from its customers. (AP Study) 2010: Netflix moves service to Level(3); Comcast disputes settlementfree peering with Level(3) 2010: FCC Makes Open Internet rules 2014: US Federal Appeals Court strikes down rules
3 June 12, 2015: FCC open internet rules No Blocking No Throttling No Paid Prioritization
4 No Paid prioritization 18. A person engaged in the provision of broadband Internet access service, insofar as such person is so engaged, shall not engage in paid prioritization. Paid prioritization refers to the management of a broadband provider s network to directly or indirectly favor some traffic over other traffic, including through use of techniques such as traffic shaping, prioritization, resource reservation, or other forms of preferential traffic management, either (a) in exchange for consideration (monetary or otherwise) from a third party, or (b) to benefit an affiliated entity.
5 Is this targeting Expedite Forwarding? No: Any form of traffic management performed by the ISP Other forms of Assured Forwarding, e.g., Class-Based Weighted Fair Queueing, aren t a way around the rules
6 Is all prioritization/bandwidth management banned? Apparently not It s only banned if it favors a third party or an affiliate
7 What if Mega Cable Company wants to favor its own video service? No problem!
8 What if the customer wants to buy a prioritized service? The customer isn t a third party or an affiliate of the ISP. It s OK to buy DIA with QoS guarantees for Voice, then resell with Voice services. Guaranteed Expedite Forward
9 No Throttling 16. A person engaged in the provision of broadband Internet access service, insofar as such person is so engaged, shall not impair or degrade lawful Internet traffic on the basis of Internet content, application, or service, or use of a non-harmful device, subject to reasonable network management.
10 No Blocking 15. A person engaged in the provision of broadband Internet access service, insofar as such person is so engaged, shall not block lawful content, applications, services, or non-harmful devices, subject to reasonable network management.
11 What about BitTorrent? Original complaints about Comcast blocking came from BitTorrent users Only lawful content is protected but how do you distinguish between legitimate BitTorrent, like Linux downloads?
12 Interfere or disadvantage 21. Any person engaged in the provision of broadband Internet access service, insofar as such person is so engaged, shall not unreasonably interfere with or unreasonably disadvantage (i) end users ability to select, access, and use broadband Internet access service or the lawful Internet content, applications, services, or devices of their choice, or (ii) edge providers ability to make lawful content, applications, services, or devices available to end users. Reasonable network management shall not be considered a violation of this rule.
13 Network Management transparency 23. A person engaged in the provision of broadband Internet access service shall publicly disclose accurate information regarding the network management practices, performance, and commercial terms of its broadband Internet access services sufficient for consumers to make informed choices regarding use of such services and for content, application, service, and device providers to develop, market, and maintain Internet offerings.
14 Large Providers Only 24. Out of an abundance of caution and in response to a request by the American Cable Association, we also adopt a temporary exemption from these enhancements for small providers (defined for the purposes of the temporary exception as providers with 100,000 or fewer subscriber)
15 What is a Broadband Internet Access Provider? 25. A mass-market retail service by wire or radio that provides the capability to transmit data to and receive data from all or substantially all Internet endpoints excluding dial-up Internet access service. BIAS does not include enterprise services, virtual private network services, hosting, or data storage services.
16 Do rules apply to every ISP Link? 30. But this Order does not apply the open Internet rules to interconnection.
17 What about a VoIP-Only link? 35. Non-Broadband Internet Access Service Data Services. The 2010 rules included an exception for specialized services. This Order likewise recognizes that some data services like facilities-based VoIP offerings, heart monitors, or energy consumption sensors may be offered by a broadband provider but do not provide access to the Internet generally.
18 Objection: First-Amendment Rights Verizon has said that open Internet Rules Violate the First Amendment by stripping ISPs of control over the transmission of speech on their networks Current Lawsuits & objection from AT&T, CenturyLink, CTIA, US Telecom
19 Objection: Fifth Amendment Net Neutrality takes network owners property without compensation by mandating that they turn over those networks for the occupation and use of others at a regulated rate of zero. -- Verizon US Constitution 5 th Amendment: No person shall be... deprived of life, liberty, or property, without due process of law; nor shall private property be taken for public use, without just compensation. Complaint in Current Lawsuits
20 Where is the congestion? No prioritization matters except while a link is congested.
21 Congested Links What could happen? 1 Netflix upgrades 2 Netflix s ISP charges Netflix more 3,4,5 Old assumptions of balanced traffic volumes aren t valid any more! Middle-ISP has to charge more to Retail-ISP 6 Retail-ISP upgrades; passes costs to Customer 7 Customer upgrades link to Netflix
22 Have we already reached the zenith of all networking? What if Netflix is genuinely harmful, and growth is unsustainable, on today s networks and business models? What if Net Neutrality is locking in today s Internet like many other rules have locked in fax? Have we already reached the zenith of all networking evolution? Shouldn t there be a way for a medical doctor-patient video conference to take precedence over a kid watching cartoons?
23 Hacking Net Neutrality 1. Prioritize your own content. The prohibitions are against deals favoring partner companies. 2. CDN. Install Content Delivery Network equipment in the ISP network to bypass most sources of congestion. 3. Buy prioritization on all the interconnection Links. 4. Buy bigger pipes to the ISP. If Netflix has 10 Gbps, Hulu only 1 Gbps, then Netflix has bought priority. 5. Push out other users of the link. Fill the link with junk data until you have real data to send 6. Don t be TCP-friendly. Make your traffic more aggressive. When other flows are slowing down in AIMD, don t do it.
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