From mboxrd@z Thu Jan 1 00:00:00 1970 Return-Path: Received: from mail-pg1-x52b.google.com (mail-pg1-x52b.google.com [IPv6:2607:f8b0:4864:20::52b]) (using TLSv1.2 with cipher ECDHE-RSA-AES128-GCM-SHA256 (128/128 bits)) (No client certificate requested) by lists.bufferbloat.net (Postfix) with ESMTPS id EFB0A3B2A4 for ; Mon, 9 Oct 2023 19:46:52 -0400 (EDT) Received: by mail-pg1-x52b.google.com with SMTP id 41be03b00d2f7-5859a7d6556so3737852a12.0 for ; Mon, 09 Oct 2023 16:46:52 -0700 (PDT) DKIM-Signature: v=1; a=rsa-sha256; c=relaxed/relaxed; d=google.com; s=20230601; t=1696895211; x=1697500011; darn=lists.bufferbloat.net; h=cc:to:subject:message-id:date:from:in-reply-to:references :mime-version:from:to:cc:subject:date:message-id:reply-to; bh=2VKcuqMhmXZ9jNgvTISF3T90qcPhirbEpfx1DljjY7s=; b=jWiAUvKqgwZFPyeRtv48p4qDWy1UJvjKg4cMNsUSV+P9fnYcbHWy3uhhEJBo6najcA fUYABpZQ89+tNyVk0D+4T0WwLfgdZM4H/oZeedevx/9vUiHh6OBtA7g6IB9xfYy3mUob PnQ2kA1zEoc4UlCYmMb4P5W0luZm2xd60dAGGkAIqyZ6aGGjTASDJU5REshzV/eGaY4f dffInzlOIKYaQJxRnTz+bHY9PIYU/B48Rc8fAEvbaEHebqenyQj17FFwCmEjl0CKPlxf ApCchXWcLXH2osOF+MLAadOuzmv0S++MF5OgzHpkWtuSklJ7GgWiVxckO51z/7ZsSIk/ 4Qyg== X-Google-DKIM-Signature: v=1; a=rsa-sha256; c=relaxed/relaxed; d=1e100.net; s=20230601; t=1696895211; x=1697500011; h=cc:to:subject:message-id:date:from:in-reply-to:references :mime-version:x-gm-message-state:from:to:cc:subject:date:message-id :reply-to; bh=2VKcuqMhmXZ9jNgvTISF3T90qcPhirbEpfx1DljjY7s=; b=IVBxHue7oyBkjOlkv/sNiXaqKDDEU269yBcXvAD/TMUzi3uH0hJT2SuGOR+M6iW5b5 lYNfTlq0sypR1C8FLI5sWUEW+rylNGLI6MfvYPoWIPmQdcIh6alE2vH7xBBD7KIGyRyg hLmq+SXgLGPlSOb/HnQ9+tpwbR2/6+Pksuv8BoP5JZDIuEQaT1cLtUkE5EI8oQEmFAJd VKvSqYrQ+Mq+oY30RBS7FSTYfAAy3Xo3pup7LY9GQIlQn386eIUTceTpphM+SDjc10Ub S69FYZDU5MgeaEE/qdzCquXfKUoIAxMb+prsBpzU6r52jrz5yEd6O9514nh3cV+RNf05 HQMg== X-Gm-Message-State: AOJu0YyC0mHyUem/yhwjVt12fKgLelcff7mrwYQRFGn4J92Vlqb2vIUT NvfXWYUAL8+eEYiFoIxH8E0hqzHYgg7Vk5e8jRyfW2pJ9dYNDVMML/pVOA== X-Google-Smtp-Source: AGHT+IEBydPioaS75I4IoS5uw3DfuP0sKGT2UN1KJIbn7i4KPzPKrkoDLlCu16nhtpywpbK3rPW2Dyw5KVSzEAQE6iI= X-Received: by 2002:a17:90a:c218:b0:26b:24ed:e0d9 with SMTP id e24-20020a17090ac21800b0026b24ede0d9mr15168140pjt.33.1696895210416; Mon, 09 Oct 2023 16:46:50 -0700 (PDT) MIME-Version: 1.0 References: <028f61d7-be24-4fe3-82d3-6eca0386d0d0@3kitty.org> <10976208-a880-4974-9f13-d84a7b5ebb6b@3kitty.org> In-Reply-To: From: Vint Cerf Date: Tue, 10 Oct 2023 08:46:26 +0900 Message-ID: To: =?UTF-8?Q?Network_Neutrality_is_back=21_Let=C2=B4s_make_the_technical_asp?= =?UTF-8?Q?ects_heard_this_time=21?= Content-Type: multipart/signed; protocol="application/pkcs7-signature"; micalg=sha-256; boundary="000000000000486c260607513463" Subject: Re: [NNagain] Introduction: Dr. David Bray X-BeenThere: nnagain@lists.bufferbloat.net X-Mailman-Version: 2.1.20 Precedence: list List-Id: =?utf-8?q?Network_Neutrality_is_back!_Let=C2=B4s_make_the_technical_aspects_heard_this_time!?= List-Unsubscribe: , List-Archive: List-Post: List-Help: List-Subscribe: , X-List-Received-Date: Mon, 09 Oct 2023 23:46:53 -0000 --000000000000486c260607513463 Content-Type: multipart/alternative; boundary="0000000000003db91c06075134ca" --0000000000003db91c06075134ca Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable David, this is a good list. FACA has rules for public participation, for example. I think it should be taken into account for any public commenting process that online (and offline such as USPS or fax and phone calls) that spam and artificial inflation of comments are possible. Is there any specific standard for US agency public comment handling? If now, what committees of the US Congress might have jurisdiction? v On Tue, Oct 10, 2023 at 8:22=E2=80=AFAM David Bray, PhD via Nnagain < nnagain@lists.bufferbloat.net> wrote: > I'm all for doing new things to make things better. > > At the same time, I used to do bioterrorism preparedness and response fro= m > 2000-2005 (and aside from asking myself what kind of crazy world needed > counter-bioterrorism efforts... I also realized you don't want to interje= ct > something completely new in the middle of an unfolding crisis event). If > something were to be injected now, it would have to have consensus from > both sides, otherwise at least one side (potentially detractors from both= ) > will claim that whatever form the new approaches take are somehow > advantaging "the other side" and disadvantaging them. > > Probably would take a ruling by the Administrative Conference of the > United States, at a minimum to answer these five questions - and even the= n, > introducing something completely different in the midst of a political > melee might just invite mudslinging unless moderate voices on both sides > can reach some consensus. > > *1. Does identity matter regarding who files a comment or not =E2=80=94 a= nd must > one be a U.S. person in order to file?* > > *2. Should agencies publish real-time counts of the number of comments > received =E2=80=94 or is it better to wait until the end of a commenting = round to > make all comments available, including counts?* > > *3. Should third-party groups be able to file on behalf of someone else o= r > not =E2=80=94 and do agencies have the right to remove spam-like comments= ?* > > *4. Should the public commenting process permit multiple comments per > individual for a proceeding =E2=80=94 and if so, how many comments from a= single > individual are too many? 100? 1000? More?* > > *5. Finally, should the U.S. government itself consider, given public > perceptions about potential conflicts of interest for any agency performi= ng > a public commenting process, whether it would be better to have third-par= ty > groups take responsibility for assembling comments and then filing those > comments via a validated process with the government?* > > > On Sat, Oct 7, 2023 at 4:10=E2=80=AFPM Jack Haverty wro= te: > >> Hi again David et al, >> >> Interesting frenzy...lots of questions that need answers and associated >> policies. I served 6 years as an elected official (in a small special >> district in California), so I have some small understanding of the >> government side of things and the constraints involved. Being in charg= e >> doesn't mean you can do what you want. >> >> I'm thinking here more near-term and incremental steps. You said "These >> same questions need pragmatic pilots that involve the public ..." >> >> So, how about using the current NN situation for a pilot? Keep all the >> current ways and emerging AI techniques to continue to flood the system >> with comments. But also offer an *optional* way for humans to "registe= r" >> as a commenter and then submit their (latest only) comment into the mele= e. >> Will people use it? Will "consumers" (the lawyers, commissioners, etc.) >> find it useful? >> >> I've found it curious, for decades now, that there are (too many) >> mechanisms for "secure email", that may help with the flood of >> disinformation from anonymous senders, but very very few people use them= . >> Maybe they don't know how; maybe the available schemes are too flawed; >> maybe ...? >> >> About 30 years ago, I was a speaker in a public meeting orchestrated by >> USPS, and recommended that they take a lead role, e.g., by acting as a >> national CA - certificate authority. Never happened though. FCC issue= s >> lots of licenses...perhaps they could issue online credentials too? >> >> Perhaps a "pilot" where you will also accept comments by email, some >> possibly sent by "verified" humans if they understand how to do so, woul= d >> be worth trying? Perhaps comments on "technical aspects" coming from >> people who demonstrably know how to use technology would be valuable to = the >> policy makers? >> >> The Internet, and technology such as TCP, began as an experimental pilot >> about 50 years ago. Sometimes pilots become infrastructures. >> >> FYI, I'm signing this message. Using OpenPGP. I could encrypt it also, >> but my email program can't find your public key. >> >> Jack Haverty >> >> >> On 10/5/23 14:21, David Bray, PhD wrote: >> >> Indeed Jack - a few things to balance - the Administrative Procedure Act >> of 1946 (on which the idea of rulemaking is based) us about raising lega= l >> concerns that must be answered by the agency at the time the rulemaking = is >> done. It's not a vote nor is it the case that if the agency gets tons of >> comments in one direction that they have to go in that direction. Instea= d >> it's only about making sure legal concerns are considered and responded = to >> before the agency before the agency acts. (Which is partly why sending "= I'm >> for XYZ" or "I'm against ABC" really doesn't mean anything to an agency = - >> not only is that not a legal argument or concern, it's also not somethin= g >> where they're obligated to follow these comments - it's not a vote or >> poll). >> >> That said, political folks have spun things to the public as if it is a >> poll/vote/chance to act. The raise a valid legal concern part of the APA= of >> 1946 is omitted. Moreover the fact that third party law firms and others >> like to submit comments on behalf of clients - there will always be a th= ird >> party submitting multiple comments for their clients (or "clients") beca= use >> that's their business. >> >> In the lead up to 2017, the Consumer and Government Affairs Bureau of th= e >> FCC got an inquiry from a firm asking how they could submit 1 million >> comments a day on an "upcoming privacy proceeding" (their words, astute >> observers will note there was no privacy proceeding before the FCC in >> 2017). When the Bureau asked me, I told them either mail us a CD to uplo= ad >> it or submit one comment with 1 million signatures. To attempt to flood = us >> with 1 million comments a day (aside from the fact who can "predict" hav= ing >> that many daily) would deny resources to others. In the mess that follow= ed, >> what was released to the public was so redacted you couldn't see the >> legitimate concerns and better paths that were offered to this entity. >> >> And the FCC isn't alone. EPA, FTC, and other regulatory agencies have ha= d >> these hijinks for years - and before the Internet it was faxes, mass >> mimeographs (remember blue ink?), and postcards.The Administrative >> Conference of the United States (ACUS) - is the body that is supposed to >> provide consistent guidance for things like this across the U.S. >> government. I've briefed them and tried to raise awareness of these issu= es >> - as I think fundamentally this is a **process** question that once >> answered, tech can support. However they're not technologies and updatin= g >> the interpretation of the process isn't something lawyers are apt to do >> until the evidence that things are in trouble is overwhelming. >> >> 52 folks wrote a letter to them - and to GSA - back in 2020. GSA had a >> rulemaking of its own on how to improve things, yet oddly never publishe= d >> any of the comments it received (including ours) and closed the rulemaki= ng >> quietly. Here's the letter: https://tinyurl.com/letter-signed-52-people >> >> And here's an article published in OODAloop about this - and why >> Generative AI is probably going to make things even more challenging: >> https://www.oodaloop.com/archive/2023/04/18/why-a-pause-on-ai-developmen= t-is-not-the-answer-an-insiders-perspective/ >> >> [snippet of the article] *Now in 2023 and Beyond: Proactive Approaches >> to AI and Society* >> >> Looking to the future, to effectively address the challenges arising fro= m >> AI, we must foster a proactive, results-oriented, and cooperative >> approach with the public >> . >> Think tanks and universities can engage the public in conversations abou= t >> how to work, live, govern, and co-exist with modern technologies that >> impact society. By involving diverse voices in the decision-making proce= ss, >> we can better address and resolve the complex challenges AI presents on >> local and national levels. >> >> In addition, we must encourage industry and political leaders to >> participate in finding non-partisan, multi-sector solutions if civil >> societies are to remain stable. By working together, we can bridge the g= ap >> between technological advancements and their societal implications. >> >> Finally, launching AI pilots across various sectors, such as work, >> education, health, law, and civil society, is essential. We must learn b= y >> doing on how we can create responsible civil environments where AIs can = be >> developed and deployed responsibly. These initiatives can help us better >> understand and integrate AI into our lives, ensuring its potential is >> harnessed for the greater good while mitigating risks. >> >> In 2019 and 2020, a group of fifty-two people asked the Administrative >> Conference of the United States >> (which helps guide >> rulemaking procedures for federal agencies), General Accounting Office, = and >> the General Services Administration to call attention to the need to >> address the challenges of chatbots flooding public commenting procedures >> and potentially crowding out or denying services to actual humans wantin= g >> to leave a comment. We asked >> >> : >> >> *1. Does identity matter regarding who files a comment or not =E2=80=94 = and must >> one be a U.S. person in order to file?* >> >> *2. Should agencies publish real-time counts of the number of comments >> received =E2=80=94 or is it better to wait until the end of a commenting= round to >> make all comments available, including counts?* >> >> *3. Should third-party groups be able to file on behalf of someone else >> or not =E2=80=94 and do agencies have the right to remove spam-like comm= ents?* >> >> *4. Should the public commenting process permit multiple comments per >> individual for a proceeding =E2=80=94 and if so, how many comments from = a single >> individual are too many? 100? 1000? More?* >> >> *5. Finally, should the U.S. government itself consider, given public >> perceptions about potential conflicts of interest for any agency perform= ing >> a public commenting process, whether it would be better to have third-pa= rty >> groups take responsibility for assembling comments and then filing those >> comments via a validated process with the government?* >> >> These same questions need pragmatic pilots that involve the public to co= -explore >> and co-develop how we operate effectively amid these technological shift= s >> . >> As the capabilities of LLMs continue to grow, we need positive change >> agents willing to tackle the messy issues at the intersection of technol= ogy >> and society. The challenges are immense, but so too are the opportunitie= s >> for positive change. Let=E2=80=99s seize this moment to create a better = tomorrow >> for all. Working together, we can co-create a future that embraces AI=E2= =80=99s >> potential while mitigating its risks >> , >> informed by the hard lessons we have already learned. >> >> Full article: >> https://www.oodaloop.com/archive/2023/04/18/why-a-pause-on-ai-developmen= t-is-not-the-answer-an-insiders-perspective/ >> >> Hope this helps. >> >> On Thu, Oct 5, 2023 at 4:44=E2=80=AFPM Jack Haverty via Nnagain < >> nnagain@lists.bufferbloat.net> wrote: >> >>> Thanks for all your efforts to keep the "feedback loop" to the >>> rulemakers functioning! >>> >>> I'd like to offer a suggestion for a hopefully politically acceptable >>> way to handle the deluge, derived from my own battles with "email" over= the >>> years (decades). >>> >>> Back in the 1970s, I implemented one of the first email systems on the >>> Arpanet, under the mentorship of JCR Licklider, who had been pursuing h= is >>> vision of a "Galactic Network" at ARPA and MIT. One of the things we >>> discovered was the significance of anonymity. At the time, anonymity = was >>> forbidden on the Arpanet; you needed an account on some computer, prote= cted >>> by passwords, in order to legitimately use the network. The mechanism= s >>> were crude and easily broken, but the principle applied. >>> >>> Over the years, that principle has been forgotten, and the right to be >>> anonymous has become entrenched. But many uses of the network, and ne= eds >>> of its users, demand accountability, so all sorts of mechanisms have be= en >>> pasted on top of the network to provide ways to judge user identity. >>> Banks, medical services, governments, and businesses all demand some wa= y of >>> proving your identity, with passwords, various schemes of 2FA, VPNs, or >>> other such technology, with varying degrees of protection. It is stil= l >>> possible to be anonymous on the net, but many things you do require you= to >>> prove, to some extent, who you are. >>> >>> So, my suggestion for handling the deluge of "comments" is: >>> >>> 1/ create some mechanism for "registering" your intent to submit a >>> comment. Make it hard for bots to register. Perhaps you can leverage= the >>> work of various partners, e.g., ISPs, retailers, government agencies, >>> financial institutions, of others who already have some way of identify= ing >>> their users. >>> >>> 2/ Also make registration optional - anyone can still submit comments >>> anonymously if they choose. >>> >>> 3/ for "registered commenters", provide a way to "edit" your previous >>> comment - i.e., advise that your comment is always the last one you >>> submitted. I.E., whoever you are, you can only submit one comment, wh= ich >>> will be the last one you submit. >>> >>> 4/ In the thousands of pages of comments, somehow flag the ones that ar= e >>> from registered commenters, visible to the people who read the comments= . >>> Even better, provide those "information consumers" with ways to sort, >>> filter, and search through the body of comments. >>> >>> This may not reduce the deluge of comments, but I'd expect it to help >>> the lawyers and politicians keep their heads above the water. >>> >>> Anonymity is an important issue for Net Neutrality too, but I'll opine >>> about that separately..... >>> >>> Jack Haverty >>> >>> >>> On 10/2/23 12:38, David Bray, PhD via Nnagain wrote: >>> >>> 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 acto= rs >>> attempted to flood the system with less-than-authentic comments. >>> >>> In some respects this is not new. The whole "notice and comment" proces= s >>> is a legacy process that goes back decades. And the FCC (and others) ha= ve >>> had postcard floods of comments, mimeographed letters of comments, faxe= d >>> 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=E2=80=99t see such volumes. When I said= there was a >>> combination of actual humans wanting to leave comments and others who w= ere >>> effectively denying service to others (especially because if anyone wan= ted >>> to do a batch upload of 100,000 comments or more they could submit a CS= V >>> file or a comment with 100,000 signatories) - both parties said no, tha= t >>> couldn=E2=80=99t be happening. >>> >>> Until 2021 when the NY Attorney General proved that was exactly what wa= s >>> 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 t= he >>> other side of the political aisle (and one or more teenagers). >>> >>> So with Net Neutrality back on the agenda - here=E2=80=99s a simple pre= diction, >>> 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=E2=80=99s lawyers spot it and r= espond to it >>> as part of the NPRM? >>> >>> Hope this helps and with highest regards, >>> >>> -d. >>> -- >>> >>> Principal, LeadDoAdapt Ventures, Inc. & >>> Distinguished Fellow >>> >>> Henry S. Stimson Center , Busi= ness >>> Executives for National Security >>> >>> >>> >>> >>> On Mon, Oct 2, 2023 at 2:15=E2=80=AFPM 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 T=C3=A4ht CSO, LibreQos >>>> _______________________________________________ >>>> Nnagain mailing list >>>> Nnagain@lists.bufferbloat.net >>>> https://lists.bufferbloat.net/listinfo/nnagain >>>> >>> >>> _______________________________________________ >>> Nnagain mailing listNnagain@lists.bufferbloat.nethttps://lists.bufferbl= oat.net/listinfo/nnagain >>> >>> >>> _______________________________________________ >>> Nnagain mailing list >>> Nnagain@lists.bufferbloat.net >>> https://lists.bufferbloat.net/listinfo/nnagain >>> >> >> _______________________________________________ > Nnagain mailing list > Nnagain@lists.bufferbloat.net > https://lists.bufferbloat.net/listinfo/nnagain > --=20 Please send any postal/overnight deliveries to: Vint Cerf Google, LLC 1900 Reston Metro Plaza, 16th Floor Reston, VA 20190 +1 (571) 213 1346 until further notice --0000000000003db91c06075134ca Content-Type: text/html; charset="UTF-8" Content-Transfer-Encoding: quoted-printable
David, this is a good list.
FACA has rules for public = participation, for example.

I think it should be t= aken into account for any public commenting process that online (and offlin= e such as USPS or fax and phone calls) that spam and artificial inflation o= f comments are possible. Is there any specific standard for US agency publi= c comment handling? If now, what committees of the US Congress might have j= urisdiction?

v


On Tue, Oct 10,= 2023 at 8:22=E2=80=AFAM David Bray, PhD via Nnagain <nnagain@lists.bufferbloat.net> wrote:=
I'm all for doing new things to make things better.

At the same time, I used to do bioterrorism preparedness = and response from 2000-2005 (and aside from asking myself what kind of craz= y world needed counter-bioterrorism efforts... I also realized you don'= t want to interject something completely new in the middle of an unfolding = crisis event). If something were to be injected now, it would have to have = consensus from both sides, otherwise at least one side (potentially detract= ors from both) will claim that whatever form the new approaches take are so= mehow advantaging "the other side" and disadvantaging them.
=

Probably would take a ruling by the Administrative Conf= erence of the United States, at a minimum to answer these five questions - = and even then, introducing something completely different in the midst of a= political melee might just invite mudslinging unless moderate voices on bo= th sides can reach some consensus.

1. Does identity matter regarding who file= s a comment or not =E2=80=94 and must one be a U.S. person in order to file= ?

2. Should agencies publish real-time counts of the number of comments=20 received =E2=80=94 or is it better to wait until the end of a commenting ro= und=20 to make all comments available, including counts?

3. Should=20 third-party groups be able to file on behalf of someone else or not =E2=80= =94=20 and do agencies have the right to remove spam-like comments?

4.=20 Should the public commenting process permit multiple comments per=20 individual for a proceeding =E2=80=94 and if so, how many comments from a s= ingle individual are too many? 100? 1000? More?

5. Finally, should the=20 U.S. government itself consider, given public perceptions about=20 potential conflicts of interest for any agency performing a public=20 commenting process, whether it would be better to have third-party=20 groups take responsibility for assembling comments and then filing those comments via a validated process with the government?

=C2=A0

On Sat, Oct 7, 2023 at 4:10=E2=80=AFPM Jack Have= rty <jack@3kitty.or= g> wrote:
=20 =20 =20
Hi again David et al,

Interesting frenzy...lots of questions that need answers and associated policies.=C2=A0=C2=A0 I served 6 years as an elected officia= l (in a small special district in California), so I have some small understanding of the government side of things and the constraints involved.=C2=A0=C2=A0 Being in charge doesn't mean you can do what = you want.

I'm thinking here more near-term and incremental steps.=C2=A0 You s= aid "These same questions need pragmatic pilots that involve the publi= c ..."

So, how about using the current NN situation for a pilot?=C2=A0 Keep al= l the current ways and emerging AI techniques to continue to flood the system with comments.=C2=A0=C2=A0 But also offer an *optional* way for = humans to "register" as a commenter and then submit their (latest on= ly) comment into the melee.=C2=A0 Will people use it?=C2=A0 Will "cons= umers" (the lawyers, commissioners, etc.) find it useful?

I've found it curious, for decades now, that there are (too many) mechanisms for "secure email", that may help with the flood o= f disinformation from anonymous senders, but very very few people use them.=C2=A0=C2=A0 Maybe they don't know how; maybe the available sc= hemes are too flawed; maybe ...?

About 30 years ago, I was a speaker in a public meeting orchestrated by USPS, and recommended that they take a lead role, e.g., by acting as a national CA - certificate authority.=C2=A0 Never happened though.= =C2=A0=C2=A0 FCC issues lots of licenses...perhaps they could issue online credentials too?

Perhaps a "pilot" where you will also accept comments by emai= l, some possibly sent by "verified" humans if they understand how to = do so, would be worth trying?=C2=A0=C2=A0 Perhaps comments on "technical = aspects" coming from people who demonstrably know how to use technology would be valuable to the policy makers?

The Internet, and technology such as TCP, began as an experimental pilot about 50 years ago.=C2=A0 Sometimes pilots become infrastructures= .

FYI, I'm signing this message.=C2=A0 Using OpenPGP.=C2=A0 I could e= ncrypt it also, but my email program can't find your public key.

Jack Haverty


On 10/5/23 14:21, David Bray, PhD wrote:
=20
Indeed Jack - a few things to balance - the Administrative Procedure Act of 1946 (on which the idea of rulemaking is based) us about raising legal concerns that must be answered by the agency at the time the rulemaking is done. It's not a vote nor is it the case that if the agency gets tons of comments in one direction that they have to go in that direction. Instead it's only about making sure legal concerns are considered and responded to before the agency before the agency acts. (Which is partly why sending "I'm for XYZ&q= uot; or "I'm against ABC" really doesn't mean anything = to an agency - not only is that not a legal argument or concern, it's also not something where they're obligated to follow these comment= s - it's not a vote or poll).

That said, political folks have spun things to the public as if it is a poll/vote/chance to act. The raise a valid legal concern part of the APA of 1946 is omitted. Moreover the fact that third party law firms and others like to submit comments on behalf of clients - there will always be a third party submitting multiple comments for their clients (or "clients&= quot;) because that's their business.

In the lead up to 2017, the Consumer and Government Affairs Bureau of the FCC got an inquiry from a firm asking how they could submit 1 million comments a day on an "upcoming privac= y proceeding" (their words, astute observers will note there w= as no privacy proceeding before the FCC in 2017). When the Bureau asked me, I told them either mail us a CD to upload it or submit one comment with 1 million signatures. To attempt to flood us with 1 million comments a day (aside from the fact who can "predict" having that many daily) would deny re= sources to others. In the mess that followed, what was released to the public was so redacted you couldn't see the legitimate concerns and better paths that were offered to this entity.

And the FCC isn't alone. EPA, FTC, and other regulatory agencies have had these hijinks for years - and before the Internet it was faxes, mass mimeographs (remember blue ink?), and postcards.The Administrative Conference of the United States (ACUS) - is the body that is supposed to provide consistent guidance for things like this across the U.S. government. I've briefed them and tried to raise awareness of these issues - as I think fundamentally this is a **process** question that once answered, tech can support. However they'r= e not technologies and updating the interpretation of the process isn't something lawyers are apt to do until the evidence that things are in trouble is overwhelming.

52 folks wrote a letter to them - and to GSA - back in 2020. GSA had a rulemaking of its own on how to improve things, yet oddly never published any of the comments it received (including ours) and closed the rulemaking quietly. Here's the letter: https://tinyurl.com/letter-signed-52-people=

And here's an article published in OODAloop about this - and why Generative AI is probably going to make things even more challenging: https://www.oodaloop.com/archive/2023/04/18/why-a-= pause-on-ai-development-is-not-the-answer-an-insiders-perspective/

[snippet of the article] Now in 2023 and Beyond: Proactive Approaches to AI and Society

Looking to the future, to effectively address the challenges arising from AI,=C2=A0we must foster a p= roactive, results-oriented, and cooperative approach with the public. Think tanks and universities can engage the public in conversations about how to work, live, govern, and co-exist with modern technologies that impact society. By involving diverse voices in the decision-making process, we can better address and resolve the complex challenges AI presents on local and national levels.

In addition, we must encourage industry and political leaders to participate in finding non-partisan, multi-sector solutions if civil societies are to remain stable. By working together, we can bridge the gap between technological advancements and their societal implications.=C2= =A0

Finally, launching AI pilots across various sectors, such as work, education, health, law, and civil society, is essential. We must learn by doing on how we can create responsible civil environments where AIs can be developed and deployed responsibly. These initiatives can help us better understand and integrate AI into our lives, ensuring its potential is harnessed for the greater good while mitigating risks.=C2=A0

In 2019 and 2020, a group of=C2=A0fifty-two people asked the Administrative Conference of the United States=C2=A0(whic= h helps guide rulemaking procedures for federal agencies), General Accounting Office, and the General Services Administration to call attention to the need to address the challenges of chatbots flooding public commenting procedures and potentially crowding out or denying services to actual humans wanting to leave a comment.=C2=A0We asked:=C2=A0

1. Does identity matter regarding who files a comment or not =E2=80=94 and must one b= e a U.S. person in order to file?

2. Should agencies publish real-time counts of the number of comments received =E2=80=94= or is it better to wait until the end of a commenting round to make all comments available, including counts?

3. Should third-party groups be able to file on behalf of someone else or not =E2=80=94 and d= o agencies have the right to remove spam-like comments?

4. Should the public commenting process permit multiple comments per individual for a proceeding =E2=80=94 and if so, how many comments from a sing= le individual are too many? 100? 1000? More?

5. Finally, should the U.S. government itself consider, given public perceptions about potential conflicts of interest for any agency performing a public commenting process, whether it would be better to have third-party groups take responsibility for assembling comments and then filing those comments via a validated process with the government?

These same questions need pragmatic pilots that involve the public to=C2=A0co-explore and co-develop how we operate effectively amid these technological shifts. As the capabilities of LLMs continue to grow, we need positive change agents willing to tackle the messy issues at the intersection of technology and society. The challenges are immense, but so too are the opportunities for positive change. Let=E2=80=99s seize this moment to create a better tomo= rrow for all. Working together,=C2=A0we can co-create a future that embraces AI=E2=80=99s potential while mitigating its risks, informed by the hard lessons we have already learned.

Full article: https://www.oodaloop.com/archive/2023/04/18/why-a-p= ause-on-ai-development-is-not-the-answer-an-insiders-perspective/

Hope this helps.


On Thu, Oct 5, 2023 at 4:44= =E2=80=AFPM Jack Haverty via Nnagain <nnagain@lists.bufferbloat.net> wrote:
Thanks for all your efforts to keep the "feedback loop= " to the rulemakers functioning!=C2=A0=C2=A0

I'd like to offer a suggestion for a hopefully politically acceptable way to handle the deluge, derived from my own battles with "email" over the years (decades).

Back in the 1970s, I implemented one of the first email systems on the Arpanet, under the mentorship of JCR Licklider, who had been pursuing his vision of a "Galactic Network" at ARPA and MIT.=C2=A0=C2=A0 One of the things we= discovered was the significance of anonymity.=C2=A0=C2=A0 At the time, ano= nymity was forbidden on the Arpanet; you needed an account on some computer, protected by passwords, in order to legitimately use the network.=C2=A0=C2=A0 The mechanisms were crude and easi= ly broken, but the principle applied.

Over the years, that principle has been forgotten, and the right to be anonymous has become entrenched.=C2=A0=C2=A0 But ma= ny uses of the network, and needs of its users, demand accountability, so all sorts of mechanisms have been pasted on top of the network to provide ways to judge user identity.=C2=A0 Banks, medical services, governments, and businesses all demand some way of proving your identity, with passwords, various schemes of 2FA, VPNs, or other such technology, with varying degrees of protection.=C2=A0=C2=A0 It = is still possible to be anonymous on the net, but many things you do require you to prove, to some extent, who you are.

So, my suggestion for handling the deluge of "comments&quo= t; is:

1/ create some mechanism for "registering" your inten= t to submit a comment.=C2=A0=C2=A0 Make it hard for bots to register= .=C2=A0 Perhaps you can leverage the work of various partners, e.g., ISPs, retailers, government agencies, financial institutions, of others who already have some way of identifying their users.

2/ Also make registration optional - anyone can still submit comments anonymously if they choose.

3/ for "registered commenters", provide a way to &quo= t;edit" your previous comment - i.e., advise that your comment is always the last one you submitted.=C2=A0=C2=A0 I.E., whoever you are, = you can only submit one comment, which will be the last one you submit.

4/ In the thousands of pages of comments, somehow flag the ones that are from registered commenters, visible to the people who read the comments.=C2=A0=C2=A0 Even better, provide = those "information consumers" with ways to sort, filter, an= d search through the body of comments.

This may not reduce the deluge of comments, but I'd expect it to help the lawyers and politicians keep their heads above the water.

Anonymity is an important issue for Net Neutrality too, but I'll opine about that separately.....

Jack Haverty


On 10/2/23 12:38, David Bray, PhD via Nnagain wrote:
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.=C2=A0

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.=C2=A0

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.=C2=A0

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=E2=80=99t see su= ch 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=E2=80=99t be happenin= g.=C2=A0

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).=C2=A0<= /div>

So with Net Neutrality back on the agenda - here=E2=80=99s 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=E2=80=99s lawyers spot it and respond to it as= part of the NPRM?

Hope this helps and with highest regards,


On Mon, Oct 2, 2023 a= t 2:15=E2=80=AFPM Dave Taht via Nnagain <nnagain@lists.bufferblo= at.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.&= quot; - Spider Robinson


--
Oct 30: https:= //netdevconf.info/0x17/news/the-maestro-and-the-music-bof.html
Dave T=C3=A4ht CSO, LibreQos
_______________________________________________
Nnagain mailing list
Nnagain@lists.bufferbloat.net
https://lists.bufferbloat.net/listin= fo/nnagain

_______________________________________________
Nnagain mailing list
Nnagain@=
lists.bufferbloat.net
https://lists.bufferbloat.net/listinfo/nnagain

_______________________________________________
Nnagain mailing list
Nnagain@lists.bufferbloat.net
https://lists.bufferbloat.net/listinfo/nnaga= in

_______________________________________________
Nnagain mailing list
Nnagain@= lists.bufferbloat.net
https://lists.bufferbloat.net/listinfo/nnagain


--
Please send any postal/overnight deliveries to:
Vint Cerf
Google, LLC
1900 Reston Metro Plaza, = 16th Floor
Reston, VA 20190
+1 (571) 213 1346
=


unti= l further notice



--0000000000003db91c06075134ca-- --000000000000486c260607513463 Content-Type: application/pkcs7-signature; name="smime.p7s" Content-Transfer-Encoding: base64 Content-Disposition: attachment; filename="smime.p7s" Content-Description: S/MIME Cryptographic Signature MIIPlwYJKoZIhvcNAQcCoIIPiDCCD4QCAQExDzANBglghkgBZQMEAgEFADALBgkqhkiG9w0BBwGg ggzxMIIEtjCCA56gAwIBAgIQeAMYYHb81ngUVR0WyMTzqzANBgkqhkiG9w0BAQsFADBMMSAwHgYD VQQLExdHbG9iYWxTaWduIFJvb3QgQ0EgLSBSMzETMBEGA1UEChMKR2xvYmFsU2lnbjETMBEGA1UE AxMKR2xvYmFsU2lnbjAeFw0yMDA3MjgwMDAwMDBaFw0yOTAzMTgwMDAwMDBaMFQxCzAJBgNVBAYT AkJFMRkwFwYDVQQKExBHbG9iYWxTaWduIG52LXNhMSowKAYDVQQDEyFHbG9iYWxTaWduIEF0bGFz IFIzIFNNSU1FIENBIDIwMjAwggEiMA0GCSqGSIb3DQEBAQUAA4IBDwAwggEKAoIBAQCvLe9xPU9W dpiHLAvX7kFnaFZPuJLey7LYaMO8P/xSngB9IN73mVc7YiLov12Fekdtn5kL8PjmDBEvTYmWsuQS 6VBo3vdlqqXZ0M9eMkjcKqijrmDRleudEoPDzTumwQ18VB/3I+vbN039HIaRQ5x+NHGiPHVfk6Rx c6KAbYceyeqqfuJEcq23vhTdium/Bf5hHqYUhuJwnBQ+dAUcFndUKMJrth6lHeoifkbw2bv81zxJ I9cvIy516+oUekqiSFGfzAqByv41OrgLV4fLGCDH3yRh1tj7EtV3l2TngqtrDLUs5R+sWIItPa/4 AJXB1Q3nGNl2tNjVpcSn0uJ7aFPbAgMBAAGjggGKMIIBhjAOBgNVHQ8BAf8EBAMCAYYwHQYDVR0l BBYwFAYIKwYBBQUHAwIGCCsGAQUFBwMEMBIGA1UdEwEB/wQIMAYBAf8CAQAwHQYDVR0OBBYEFHzM CmjXouseLHIb0c1dlW+N+/JjMB8GA1UdIwQYMBaAFI/wS3+oLkUkrk1Q+mOai97i3Ru8MHsGCCsG AQUFBwEBBG8wbTAuBggrBgEFBQcwAYYiaHR0cDovL29jc3AyLmdsb2JhbHNpZ24uY29tL3Jvb3Ry MzA7BggrBgEFBQcwAoYvaHR0cDovL3NlY3VyZS5nbG9iYWxzaWduLmNvbS9jYWNlcnQvcm9vdC1y My5jcnQwNgYDVR0fBC8wLTAroCmgJ4YlaHR0cDovL2NybC5nbG9iYWxzaWduLmNvbS9yb290LXIz LmNybDBMBgNVHSAERTBDMEEGCSsGAQQBoDIBKDA0MDIGCCsGAQUFBwIBFiZodHRwczovL3d3dy5n bG9iYWxzaWduLmNvbS9yZXBvc2l0b3J5LzANBgkqhkiG9w0BAQsFAAOCAQEANyYcO+9JZYyqQt41 TMwvFWAw3vLoLOQIfIn48/yea/ekOcParTb0mbhsvVSZ6sGn+txYAZb33wIb1f4wK4xQ7+RUYBfI TuTPL7olF9hDpojC2F6Eu8nuEf1XD9qNI8zFd4kfjg4rb+AME0L81WaCL/WhP2kDCnRU4jm6TryB CHhZqtxkIvXGPGHjwJJazJBnX5NayIce4fGuUEJ7HkuCthVZ3Rws0UyHSAXesT/0tXATND4mNr1X El6adiSQy619ybVERnRi5aDe1PTwE+qNiotEEaeujz1a/+yYaaTY+k+qJcVxi7tbyQ0hi0UB3myM A/z2HmGEwO8hx7hDjKmKbDCCA18wggJHoAMCAQICCwQAAAAAASFYUwiiMA0GCSqGSIb3DQEBCwUA MEwxIDAeBgNVBAsTF0dsb2JhbFNpZ24gUm9vdCBDQSAtIFIzMRMwEQYDVQQKEwpHbG9iYWxTaWdu MRMwEQYDVQQDEwpHbG9iYWxTaWduMB4XDTA5MDMxODEwMDAwMFoXDTI5MDMxODEwMDAwMFowTDEg MB4GA1UECxMXR2xvYmFsU2lnbiBSb290IENBIC0gUjMxEzARBgNVBAoTCkdsb2JhbFNpZ24xEzAR BgNVBAMTCkdsb2JhbFNpZ24wggEiMA0GCSqGSIb3DQEBAQUAA4IBDwAwggEKAoIBAQDMJXaQeQZ4 Ihb1wIO2hMoonv0FdhHFrYhy/EYCQ8eyip0EXyTLLkvhYIJG4VKrDIFHcGzdZNHr9SyjD4I9DCuu l9e2FIYQebs7E4B3jAjhSdJqYi8fXvqWaN+JJ5U4nwbXPsnLJlkNc96wyOkmDoMVxu9bi9IEYMpJ pij2aTv2y8gokeWdimFXN6x0FNx04Druci8unPvQu7/1PQDhBjPogiuuU6Y6FnOM3UEOIDrAtKeh 6bJPkC4yYOlXy7kEkmho5TgmYHWyn3f/kRTvriBJ/K1AFUjRAjFhGV64l++td7dkmnq/X8ET75ti +w1s4FRpFqkD2m7pg5NxdsZphYIXAgMBAAGjQjBAMA4GA1UdDwEB/wQEAwIBBjAPBgNVHRMBAf8E BTADAQH/MB0GA1UdDgQWBBSP8Et/qC5FJK5NUPpjmove4t0bvDANBgkqhkiG9w0BAQsFAAOCAQEA S0DbwFCq/sgM7/eWVEVJu5YACUGssxOGhigHM8pr5nS5ugAtrqQK0/Xx8Q+Kv3NnSoPHRHt44K9u bG8DKY4zOUXDjuS5V2yq/BKW7FPGLeQkbLmUY/vcU2hnVj6DuM81IcPJaP7O2sJTqsyQiunwXUaM ld16WCgaLx3ezQA3QY/tRG3XUyiXfvNnBB4V14qWtNPeTCekTBtzc3b0F5nCH3oO4y0IrQocLP88 q1UOD5F+NuvDV0m+4S4tfGCLw0FREyOdzvcya5QBqJnnLDMfOjsl0oZAzjsshnjJYS8Uuu7bVW/f hO4FCU29KNhyztNiUGUe65KXgzHZs7XKR1g/XzCCBNAwggO4oAMCAQICEAG/h5ZiH7Y4815iq/th nt8wDQYJKoZIhvcNAQELBQAwVDELMAkGA1UEBhMCQkUxGTAXBgNVBAoTEEdsb2JhbFNpZ24gbnYt c2ExKjAoBgNVBAMTIUdsb2JhbFNpZ24gQXRsYXMgUjMgU01JTUUgQ0EgMjAyMDAeFw0yMzA3MjMx MzIwNDRaFw0yNDAxMTkxMzIwNDRaMCAxHjAcBgkqhkiG9w0BCQEWD3ZpbnRAZ29vZ2xlLmNvbTCC ASIwDQYJKoZIhvcNAQEBBQADggEPADCCAQoCggEBALt6lfq1Df5y+axmhOcln+xEroS9ECyvXulr 0YJrYUFAfZWcMF4wHKBIaiJoRgigoH54oj0ZJONAwwHu5MsSbQOzA4xG9z7sQS2+COjdBbO3r6ZL XiFIejuawlzgjqbYPGHNjEvrtrTWYRIT/JJVQiQb4ydYYunqRYitbRQ7LmKgd0eEwHukcYdy9vko nlwMMCFxkOxzCnu118NIfFEEigR8+Iga1HX5cE6hiyCoE5GGC7vyQnNj7wYoKHZkan4yqTos+xir 1RZ4kS4q6gtOD5unmxmP0+Mq01txSBmRTJA/V/KAx1XW6Gff9woDrtQ4R5on/SHelnUotVKnznwL xLkCAwEAAaOCAdAwggHMMBoGA1UdEQQTMBGBD3ZpbnRAZ29vZ2xlLmNvbTAOBgNVHQ8BAf8EBAMC BaAwHQYDVR0lBBYwFAYIKwYBBQUHAwQGCCsGAQUFBwMCMB0GA1UdDgQWBBQrocHqVFFn5Qu8tf6r SIxBQtZIbTBMBgNVHSAERTBDMEEGCSsGAQQBoDIBKDA0MDIGCCsGAQUFBwIBFiZodHRwczovL3d3 dy5nbG9iYWxzaWduLmNvbS9yZXBvc2l0b3J5LzAMBgNVHRMBAf8EAjAAMIGaBggrBgEFBQcBAQSB jTCBijA+BggrBgEFBQcwAYYyaHR0cDovL29jc3AuZ2xvYmFsc2lnbi5jb20vY2EvZ3NhdGxhc3Iz c21pbWVjYTIwMjAwSAYIKwYBBQUHMAKGPGh0dHA6Ly9zZWN1cmUuZ2xvYmFsc2lnbi5jb20vY2Fj ZXJ0L2dzYXRsYXNyM3NtaW1lY2EyMDIwLmNydDAfBgNVHSMEGDAWgBR8zApo16LrHixyG9HNXZVv jfvyYzBGBgNVHR8EPzA9MDugOaA3hjVodHRwOi8vY3JsLmdsb2JhbHNpZ24uY29tL2NhL2dzYXRs YXNyM3NtaW1lY2EyMDIwLmNybDANBgkqhkiG9w0BAQsFAAOCAQEAUbN/EBRBmbSQuzm5OOKc6wiX tZO+O3+f8oGtpWESn5tLpBnxMB90r+2PoMMREKPrK2JvNJeEaLs4cSbB7GPrhnY6t3UoXq2Z37Wj oKAQUDTbvkf2bTKtwbjukQ07Hm/DLbjWi3PvjmCLfqGWiJbOSk2AhMIgm8LtIpZG2MxRKZ2lDBDS CUN44mnyUBKh219itnfcYBbpm4xTV5tcMBtdy/eyWtVkQF4SqUXVpA8ZxTYi79AmUxm6+vdMmfTa 4B4uRAmHf5CTXxTxFeWa9h3DGWzWXptgT1QS1SeDKU/ylauO1iWxy8t9si4pRsyWdAGneHgATocU 7tew5FshRKvVpDGCAmowggJmAgEBMGgwVDELMAkGA1UEBhMCQkUxGTAXBgNVBAoTEEdsb2JhbFNp Z24gbnYtc2ExKjAoBgNVBAMTIUdsb2JhbFNpZ24gQXRsYXMgUjMgU01JTUUgQ0EgMjAyMAIQAb+H lmIftjjzXmKr+2Ge3zANBglghkgBZQMEAgEFAKCB1DAvBgkqhkiG9w0BCQQxIgQgoDIrefeTDHBH /LNOaj4220xNuLBZAoQZUWeGRp83jRQwGAYJKoZIhvcNAQkDMQsGCSqGSIb3DQEHATAcBgkqhkiG 9w0BCQUxDxcNMjMxMDA5MjM0NjUxWjBpBgkqhkiG9w0BCQ8xXDBaMAsGCWCGSAFlAwQBKjALBglg hkgBZQMEARYwCwYJYIZIAWUDBAECMAoGCCqGSIb3DQMHMAsGCSqGSIb3DQEBCjALBgkqhkiG9w0B AQcwCwYJYIZIAWUDBAIBMA0GCSqGSIb3DQEBAQUABIIBAGIfrhninUiPolikQrXbX7rvHfKbNjPE BsrgJDD1VS8GDPF1o8jbtzcUCkXdyA8L4qAU3/k80iug/MaLCyGQmvvmFxF1GHm4Xcd0t5+Ni5YT FHCO2aDSa5MpoVJpiLPKukbYelRENy/npoTeuKGopeRJdxWRFmsnVB26gvuOAXBbah8wR9bm0ZwE iRUBhHHLNQc3Lq5NCIePSVQiGd7YrqFxo/7ox+uJ4oVXbHrgmWlvBOO8oOxkeN7+xOVQaAqIvEKt PlkfmQcRl5ncd0v56RcOFIRuHyMmY/waJPXRPyv93KZBZOscP+GcQws2HOoaCDKeuRZ13TQR/g35 kizPNuA= --000000000000486c260607513463--