Greetings all and thank you Dave Taht for that very kind intro...

First, I'll open with I'm a gosh-darn non-partisan, which means I swore an
oath to uphold the Constitution first and serve the United States - not a
specific party, tribe, or ideology. This often means, especially in today's
era of 24/7 news and social media, non-partisans have to "top cover".

Second, I'll share that in what happened in 2017 (which itself was 10x what
we saw in 2014) my biggest concern was and remains that a few actors
attempted to flood the system with less-than-authentic comments.

In some respects this is not new. The whole "notice and comment" process is
a legacy process that goes back decades. And the FCC (and others) have had
postcard floods of comments, mimeographed letters of comments, faxed floods
of comments, and now this - which, when combined with generative AI, will
be yet another flood.

Which gets me to my biggest concern as a non-partisan in 2023-2024, namely
how LLMs might misuse and abuse the commenting process further.

Both in 2014 and 2017, I asked FCC General Counsel if I could use CAPTChA
to try to reduce the volume of web scrapers or bots both filing and pulling
info from the Electronic Comment Filing System.

Both times I was told *no* out of concerns that they might prevent someone
from filing. I asked if I could block obvious spam, defined as someone
filing a comment >100 times a minute, and was similarly told no because one
of those possible comments might be genuine and/or it could be an ex party
filing en masse for others.

For 2017 we had to spin up 30x the number of AWS cloud instances to handle
the load - and this was a flood of comments at 4am, 5am, and 6am ET at
night which normally shouldn’t see such volumes. When I said there was a
combination of actual humans wanting to leave comments and others who were
effectively denying service to others (especially because if anyone wanted
to do a batch upload of 100,000 comments or more they could submit a CSV
file or a comment with 100,000 signatories) - both parties said no, that
couldn’t be happening.

Until 2021 when the NY Attorney General proved that was exactly what was
happening with 18m of the 23m apparently from non-authentic origin with ~9m
from one side of the political aisle (and six companies) and ~9m from the
other side of the political aisle (and one or more teenagers).

So with Net Neutrality back on the agenda - here’s a simple prediction,
even if the volume of comments is somehow controlled, 10,000+ pages of
comments produced by ChatGPT or a different LLM is both possible and
probably will be done. The question is if someone includes a legitimate
legal argument on page 6,517 - will FCC’s lawyers spot it and respond to it
as part of the NPRM?

Hope this helps and with highest regards,

-d.
-- 

Principal, LeadDoAdapt Ventures, Inc. <https://www.leaddoadapt.com/> &
Distinguished Fellow

Henry S. Stimson Center <https://www.stimson.org/ppl/david-bray/>, Business
Executives for National Security <https://bens.org/people/dr-david-bray/>



On Mon, Oct 2, 2023 at 2:15 PM Dave Taht via Nnagain <
nnagain@lists.bufferbloat.net> wrote:

> All:
>
> I have spent the last several days reaching out to as many people I
> know with a deep understanding of the policy and technical issues
> surrounding the internet, to participate on this list. I encourage you
> all to reach out on your own, especially to those that you can
> constructively and civilly disagree with, and hopefully work with, to
> establish technical steps forward. Quite a few have joined silently!
> So far, 168 people have joined!
>
> Please welcome Dr David Bray[1], a self-described "human flack jacket"
> who, in the last NN debate, stood up for the non -partisan FCC IT team
> that successfully kept the system up 99.4% of the time despite the
> comment floods and network abuses from all sides. He has shared with
> me privately many sad (and some hilarious!) stories of that era, and I
> do kind of hope now, that some of that history surfaces, and we can
> learn from it.
>
> Thank you very much, David, for putting down your painful memories[2],
> and agreeing to join here. There is a lot to tackle here, going
> forward.
>
> [1] https://www.stimson.org/ppl/david-bray/
> [2] "Pain shared is reduced. Joy shared, increased." - Spider Robinson
>
>
> --
> Oct 30:
> https://netdevconf.info/0x17/news/the-maestro-and-the-music-bof.html
> Dave Täht CSO, LibreQos
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>