From mboxrd@z Thu Jan 1 00:00:00 1970 Return-Path: Received: from bosmailout06.eigbox.net (bosmailout06.eigbox.net [66.96.187.6]) (using TLSv1.2 with cipher ECDHE-RSA-AES256-GCM-SHA384 (256/256 bits)) (No client certificate requested) by lists.bufferbloat.net (Postfix) with ESMTPS id E65043B29D for ; Tue, 10 Oct 2023 15:39:06 -0400 (EDT) Received: from bosmailscan09.eigbox.net ([10.20.15.9]) by bosmailout06.eigbox.net with esmtp (Exim) id 1qqIZO-000582-7r for nnagain@lists.bufferbloat.net; Tue, 10 Oct 2023 15:39:06 -0400 DKIM-Signature: v=1; a=rsa-sha256; q=dns/txt; c=relaxed/relaxed; d=alum.mit.edu; s=dkim; h=Sender:Content-Type:MIME-Version:Message-ID:Date: Subject:In-Reply-To:References:Cc:To:From:Reply-To:Content-Transfer-Encoding: Content-ID:Content-Description:Resent-Date:Resent-From:Resent-Sender: Resent-To:Resent-Cc:Resent-Message-ID:List-Id:List-Help:List-Unsubscribe: List-Subscribe:List-Post:List-Owner:List-Archive; bh=PXdB4yY6t5n3/aHtEG/9Mfi3h7SlNtY1grzyaao2QGc=; b=2ZglddhuczgOdvtCKp0d/Kcp0A /u7mF02Z0G1xdGVfymLHtcLILPHkM6Lvr0mSK9Lok64HtMcTDVSU/YT0eqm0C3cgzWYKzfp6Arxlj 6xmGq46nSVuNCzeK8AVX74tR96g3nlrjOs1/rPCavnIPOitUiYxAA5LeMZz0NSExXkKZLH5TPecOP QEghYDUsTgNKB+DdzeMYmi/yxhFWL7YBSl3I4WVpZqNuwwGLzOj7IcZmRM3F5ysWgZuhxFupjVUdD o94aLV9ZfY6DSvghwWiSdLeXyU8jtLcyIZ5SjxVG+dGQXxh+nPozkzAliRvjO2Tdf7yOqJLxobGAt jm0l4hkQ==; Received: from [10.115.3.33] (helo=bosimpout13) by bosmailscan09.eigbox.net with esmtp (Exim) id 1qqIZN-00029H-UE for nnagain@lists.bufferbloat.net; Tue, 10 Oct 2023 15:39:05 -0400 Received: from bosauthsmtp02.yourhostingaccount.com ([10.20.18.2]) by bosimpout13 with id wKf22A00K02gpmq01Kf5wl; Tue, 10 Oct 2023 15:39:05 -0400 X-Authority-Analysis: v=2.3 cv=G76H7+s5 c=1 sm=1 tr=0 a=9MP9vxlQrmnoeofDS6o88g==:117 a=tKttg/DTfI8zZz0UFxdR5w==:17 a=bhdUkHdE2iEA:10 a=r77TgQKjGQsHNAKrUKIA:9 a=kurRqvosAAAA:8 a=b5pD3H2tAAAA:8 a=zGrw6BzrAAAA:8 a=0hPvIJo2AAAA:8 a=kopILD-HAAAA:20 a=1XWaLZrsAAAA:8 a=bILXjT4uAAAA:8 a=jJsLznCJAAAA:8 a=xyqgUZQ-InmViQsjKUcA:9 a=QEXdDO2ut3YA:10 a=SSmOFEACAAAA:8 a=djgCFnv-8RSnLQkWt6MA:9 a=5SJv12KhthdIufmE:21 a=gKO2Hq4RSVkA:10 a=UiCQ7L4-1S4A:10 a=hTZeC7Yk6K0A:10 a=frz4AuCg-hUA:10 a=kbxRQ_lfPIoQnHsAj2-A:22 a=187z9LzzJ7CMHtfju3H9:22 a=gb3rfwluTT-eQqXgGhoe:22 a=S3_905-VkIf9tT_g5NzZ:22 a=gFXG8G1-4AZNkDzM2LB8:22 a=3oJy0-Wczx8RRCKpTMhW:22 a=ZT_8zCgGubuJgGonBfBE:22 Received: from c-73-158-253-41.hsd1.ca.comcast.net ([73.158.253.41]:61387 helo=SRA6) by bosauthsmtp02.eigbox.net with esmtpa (Exim) id 1qqIZJ-0006g3-F0; Tue, 10 Oct 2023 15:39:02 -0400 Reply-To: From: "Dick Roy" To: =?UTF-8?Q?'Network_Neutrality_is_back!_Let?= =?UTF-8?Q?=C2=B4s_make_the_technical_aspects_he?= =?UTF-8?Q?ard_this_time!'?= References: <028f61d7-be24-4fe3-82d3-6eca0386d0d0@3kitty.org> <10976208-a880-4974-9f13-d84a7b5ebb6b@3kitty.org> <319cc107-f753-4e2a-8b72-6595117ae37b@3kitty.org> <48361881-9465-4c85-b726-ce7c7f565632@3kitty.org> <575d8624-0c42-4090-b6fb-7a9b224f130d@rjmcmahon.com> In-Reply-To: <575d8624-0c42-4090-b6fb-7a9b224f130d@rjmcmahon.com> Date: Tue, 10 Oct 2023 12:38:59 -0700 Organization: SRA Message-ID: MIME-Version: 1.0 Content-Type: multipart/alternative; boundary="----=_NextPart_000_0266_01D9FB76.BFC93E90" X-Mailer: Microsoft Office Outlook 11 Thread-Index: Adn7rClNg32rxE67Qg2+J1wqzhzuyQAAvLNg X-MimeOLE: Produced By Microsoft MimeOLE X-EN-UserInfo: f809475445fb8041985048e338e1a001:931c98230c6409dcc37fa7e93b490c27 X-EN-AuthUser: dickroy@intellicommunications.com Sender: "Dick Roy" X-EN-OrigIP: 73.158.253.41 X-EN-OrigHost: c-73-158-253-41.hsd1.ca.comcast.net Subject: Re: [NNagain] somewhat OT: Licklidder 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: Tue, 10 Oct 2023 19:39:07 -0000 This is a multi-part message in MIME format. ------=_NextPart_000_0266_01D9FB76.BFC93E90 Content-Type: text/plain; charset="UTF-8" Content-Transfer-Encoding: quoted-printable =20 =20 _____ =20 From: Nnagain [mailto:nnagain-bounces@lists.bufferbloat.net] On Behalf = Of Robert McMahon via Nnagain Sent: Tuesday, October 10, 2023 12:01 PM To: Jack Haverty via Nnagain Cc: Robert McMahon Subject: Re: [NNagain] somewhat OT: Licklidder =20 Thanks for sharing. It's amazing to me what was accomplished and = continues forward with communications & compute by extremely phenomenal = people. I think the closest analog is the Gutenberg press, which many = know had profound effects on the human condition. A hope is that we = figure out how to progress in a similar manner, and somehow, the = diffusion of knowledge and peaceful coexistence prevail. https://www.crf-usa.org//bill-of-rights-in-action/bria-24-3-b-gutenberg-a= nd-the-printing-revolution-in-europe#:~:text=3DJohann%20Gutenberg%27s%20i= nvention%20of%20movable,split%20apart%20the%20Catholic%20Church = . Johann Gutenberg=E2=80=99s invention of movable-type printing quickened = the spread of knowledge, discoveries, and literacy in Renaissance = Europe. The printing revolution also contributed mightily to the = Protestant Reformation that split apart the Catholic Church. [RR] It is claimed by many to be the achievement that most profoundly = affected humanity over the last two millennia! Hard to disagree IMO! Cheers, RR Bob On Oct 10, 2023, at 10:12 AM, Jack Haverty via Nnagain = wrote: FYI, The Arpanet was a key player in that patent fight. The Arpanet=20 IMPs (the packet switches) downloaded software from each other, and that = capability was used to distribute new releases of the IMP program. I=20 suggested that 1970s implementation to the lawyers as a good example of=20 prior art, which led to a lot of work that eventually resurrected the=20 1970s IMP code from a moldy listing in someone's basement, and got it=20 running again on simulated ancient hardware. At one point the 4-node=20 Arpanet of 1970 was created and run, in anticipation of a demo of prior=20 art at trial. Sadly (for me at least) the combatants suddenly settled=20 out of court, so the trial never happened and the patent issue was not=20 adjudicated. But the resurrected IMP code is on github now, so anyone=20 interested can run their own Arpanet. Jack On 10/10/23 08:53, Steve Crocker via Nnagain wrote: Lots of good stuff here and I missed the earlier posts, but one small=20 thing caught my attention: About 10 years ago, I accidentally got involved in a patent dispute to be an "expert witness", for a patent involving downloading new programs over a communications path into a remote computer (yes, what all our devices do almost every day). In the seminal period of late 1968 and early 1969 when we were=20 thinking about Arpanet protocols, one idea that was very much part of=20 our thinking was downloading a small program at the beginning of an=20 interactive session. The downloaded program would take care of local=20 interactions to avoid the need to send every character across the net=20 only to have it echoed remotely. Why not always use local echo? =20 Because most of the time-shared systems in the various ARPA-supported=20 research environments had distinct ways of interpreting each and=20 every character. Imposing a network-wide rule of local echoing would=20 have compromised the usability of most of the systems on the Arpanet. =20 I think Multics was the only "modern" line-at-a-time system at the = time. In March 1969 we decided it was time to write down the ideas from our=20 meetings in late 1968 and early 1969. The first batch of RFCs=20 included Rulifson's RFC 5. He proposed DEL, the Decode-Encode=20 Language. Elie's RFC 51 a year later proposed the Network Interchange=20 Language. In both cases the basic concept was the creation of a=20 simple language, easily implementable on each platform, that would=20 mediate the interaction with a remote system. The programs were=20 expected to be short -- hence downloadable quickly -- and either=20 interpreted or quickly translated. There was a tiny bit of=20 experimental work along this line, but it was far ahead of its time. =20 I think it was about 25 years before ActiveX came along, followed by = Java. Steve On Tue, Oct 10, 2023 at 11:30=E2=80=AFAM Dave Taht via Nnagain=20 wrote: On Mon, Oct 9, 2023 at 7:56=E2=80=AFPM Jack Haverty via Nnagain wrote: For starters it is an honor to be conversing with folk that knew = Bob Taylor, and "Lick", and y'all made me go back and re-read http://memex.org/licklider.pdf For inspiration. I think everyone in our field should re-read that, periodically. For example he makes an overgeneralization about the thinking processes of men, as compared to the computers of the = time, and not to women... But I have always had an odd question - what songs did Lick play on guitar? Do any recordings exist? Music defines who I am, at least. I love the angularness and = surprises in jazz, and the deep storytelling buried deep in Shostakovich's Fifth. Moving forward to modern music: the steady backbeat of = Burning Man - and endless repetition of short phrases - seems to lead to groupthink - I can hardly stand EDM for an hour. I am "maked" by Angela' Lansbury's Sweeny Todd, and my religion, forever reformed by Monty Python's Life of Brian, One Flew over the Cookoos nest, 12 Angry Men, and the 12 Monkees, Pink Floyd and punk music were the things that shaped me. No doubt it differs significantly for everyone here, please share? Powerful tales and their technologies predate the internet, and because they were wildly shared, influenced how generations thought without being the one true answer. Broadcast media, also, was = joint, and in school we We are in a new era of uncommonality of experience, in part from bringing in all the information in the world, while still separated = by differences in language, exposure, education, and culture, although nowadays it has become so easy and natural to be able to use = computer assisted language translation tools, I do not know how well they = truly make the jump between cultures. In that paper he talked about 75% of his time being spent setting = up to do analytics, where today so much information exists as to be impossible to analyze. I only have a few more small comments below, but I wanted to pick = out the concepts of TOS and backpressure as needing thought on another day, in another email (what was licks song list??? :)). The = internet has very little Tos or backpressure, and Flow Queuing based = algorithms actually function thusly: If the arrival rate of a flow is less than the departure rate of = all other flows, it goes out first. To some extent this matches some of Nagles' "every application has = a right to one packet in the network", and puts a reward into the = system for applications that use slightly less than their fair share of = the bandwidth. IMHO, the problem may be that the Internet, and computing technology in general, is so new that non-technical organizations, such as government entities, don't understand it and therefore can't figure out whether or how to regulate anything involved. In other, older, "technologies", rules, procedures, and traditions have developed over the years to provide for feedback and control between governees and governors. Roberts Rules of Order was created 150 years ago, and is still widely used to manage public meetings. I've been in local meetings where everyone gets a chance to speak, but are limited to a few minutes to say whatever's on their mind. You have to appear in person, wait your turn, and make your comment. Doing so is free, but still has the cost of time and hassle to get to the meeting. Organizations have figured out over the years how to manage meetings. [Vint - remember the "Rathole!" mechanism that we used to keep Internet meetings on track...?] PARC had "Dealer". From what David describes, it sounds like the current "public comment" mechanisms in the electronic arena are only at the stage where the loudest voices can drown out all others, and public debates are essentially useless cacophonies of the loudest proponents of the various viewpoints. There are no rules. Why should anyone submit their own sensible comments, knowing they'll be lost in the noise? In non-electronic public forums, such behavior is ruled out, and if it persists, the governing body can have offenders ejected, adjourn a meeting until cooler heads prevail, or otherwise make the discourse useful for informing decisions. Courts can issue restraining orders, but has any court ever issued such an order applying to an electronic forum? So, why haven't organizations yet developed rules and mechanisms for managing electronic discussions....? I'd offer two observations and suggestions. ----- First, a major reason for a lack of such rules and mechanisms may be an educational gap. Administrators, politicians, and staffers may simply not understand all this newfangled technology, or how it works, and are drowning in a sea of terminology, acronyms, and concepts that make no sense (to them). In the FCC case, even the technical gurus may have deep knowledge of their traditional realm of telephony, radio, and related issues and policy tradeoffs. But they may be largely ignorant of computing and networking equivalents. Probably even worse, they may unconsciously consider the new world as a simple evolution of the old, not recognizing the impact of incredibly fast computers and communications, and the advances that they enable, such as "AI" - whatever that is... About 10 years ago, I accidentally got involved in a patent dispute to be an "expert witness", for a patent involving downloading new programs over a communications path into a remote computer (yes, what all our devices do almost every day). I was astounded when I learned how little the "judicial system" (lawyers, judges, legislators, etc.) knew about computer and network technology. That didn't stop them from debating the meaning of technical terms. What is RAM? How does "programming" differ from "reprogramming"? What is "memory"? What is a "processor"? What is an "operating system"? The arguments continue until eventually a judge declares what the answer is, with little technical knowledge or expertise to help. So you can easily get legally binding definitions such as "operating system" means "Windows", and that all computers contain an operating = system. I spent hours on the phone over about 18 months, explaining to the lawyers how computers and networks actually worked. In turn, they taught me quite a lot about the vagaries of the laws and patents. It was fascinating but also disturbing to see how ill-prepared the legal system was for new technologies. So, my suggestion is that a focus be placed on helping the non-technical decision makers understand the nuances of computing and the Internet. I don't think that will be successful by burying them in the sea of technical jargon and acronyms. Before I retired, I spent a lot of time with C-suite denizens from companies outside of the technology industry - banks, manufacturers, transportation, etc. - helping them understand what "The Internet" was, and help them see it as both a huge opportunity and a huge threat to their businesses. One technique I used was simply stolen from the early days of The Internet. When we were involved in designing the internal mechanisms of the Internet, in particular TCPV4, we didn't know much about networks either. So we used analogies. In particular we used the existing transportation infrastructure as a model. Moving bits around the world isn't all that different from moving goods and people. But everyone, even with no technical expertise, knows about transportation. It turns out that there are a lot of useful analogies. For example, we recognized that there were different kinds of "traffic" with different needs. Coal for power plants was important, but not urgent. If a coal train waits on a siding while a passenger train passes, it's OK, even preferred. There could be different "types of service" available from the transportation infrastructure. At the time (late 1970s) we didn't know exactly how to do that, but decided to put a field in the IP header as a placeholder - the "TOS" field. Figuring out what different TOSes there should be, and how they would be handled differently, was still on the to-do list. There are even analogies to the Internet - goods might travel over a "marine network" to a "port", where they are moved onto a "rail network", to a distributor, and moved on the highway network to their final destination. Routers, gateways, ... Other transportation analogies reinforced the notion of TOS.=20 E.g., if you're sending a document somewhere, you can choose how to send it - normal postal mail, or Priority Mail, or even use a different "network" such as an overnight delivery service.=20 Different TOS would engage different behaviors of the underlying communications system, and might also have different costs to use them. Sending a ton of coal to get delivered in a week or two would cost a lot less than sending a ton of documents for overnight delivery. There were other transportation analogies heard during the TCPV4 design discussions - e.g., "Expressway Routing" (do you take a direct route over local streets, or go to the freeway even though it's longer) and "Multi-Homing" (your manufacturing plant has access to both a highway and a rail line). Suggestion -- I suspect that using a familiar infrastructure such as transport to discuss issues with non-technical decision makers would be helpful. E.g., imagine what would happen if some particular "net neutrality" set of rules was placed on the transportation infrastructure? Would it have a desirable effect? ----- Second, in addition to anonymity as an important issue in the electronic world, my experience as a mentee of Licklider surfaced another important issue in the "galactic network" vision -- "Back Pressure". The notion is based in existing knowledge.=20 Economics has notions of Supply and Demand and Cost Curves.=20 Engineering has the notion of "Negative Feedback" to stabilize mechanical, electrical, or other systems. We discussed Back Pressure, in the mid 70s, in the context of electronic mail, and tried to get the notion of "stamps" accepted as part of the email mechanisms. The basic idea was that there had to be some form of "back pressure" to prevent overload by discouraging sending of huge quantities of mail. At the time, mail traffic was light, since every message was typed by hand by some user. In Lick's group we had experimented with using email as a way for computer programs to interact. In Lick's vision, humans would interact by using their computers as their agents. Even then, computers could send email a lot faster and continuously than any human at a keyboard, and could easily flood the network. [This epiphany occurred shortly after a mistake in configuring distribution lists caused so many messages and replies that our machine crashed as its disk space ran out.] "Stamps" didn't necessarily represent monetary cost. Back pressure could be simple constraints, e.g., no user can send more than 500 (or whatever) messages per day. This notion never got enough support to become part of the email standards; I still think it would help with the deluge of spam we all experience = today. Back Pressure in the Internet today is largely non-existent. I (or my AI and computers) can send as much email as I like.=20 Communications carriers promote "unlimited data" but won't guarantee anything. Memory has become cheap, and as a result behaviors such as "buffer bloat" have appeared. Suggestion - educate the decision-makers about Back Pressure, using highway analogies (metering lights, etc.) ----- Education about the new technology, but by using some familiar analogs, and introduction of Back Pressure, in some appropriate form, as part of a "network neutrality" policy, would be the two foci I'd recommend. My prior suggestion of "registration" and accepting only the last comment was based on the observations above. Back pressure doesn't have to be monetary, and registered users don't have to be personally identified. Simply making it sufficiently "hard" to register (using CAPTCHAs, 2FA, whatever) would be a "cost" discouraging "loud voices". Even the law firms submitting millions of comments on behalf of their clients might balk at the cost (in labor not money) to register their million clients, even anonymously, so each could get his/her comment submitted. Of course, they could always pass the costs on to their (million? really?) clients. But it would still be Back Pressure. One possibility -- make the "cost" of submitting a million electronic comments equal to the cost of submitting a million postcards...? Jack Haverty On 10/9/23 16:55, David Bray, PhD wrote: Great points Vint as you're absolutely right - there are multiple modalities here (and in the past it was spam from thousands of postcards, then mimeographs, then faxes, etc.) The standard historically has been set by the Administrative Conference of the United States: https://www.acus.gov/about-acus In 2020 there seemed to be an effort to gave the General Services Administration weigh-in, however they closed that rulemaking attempt without publishing any of the comments they got and no announcement why it was closed. As for what part of Congress - I believe ACUS was championed by both the Senate and House Judiciary Committees as it has oversight and responsibility for the interpretations of the Administrative Procedure Act of 1946 (which sets out the whole rulemaking = procedure). Sadly there isn't a standard across agencies - which also means there isn't a standard across Administrations. Back in 2018 and 2020, both with this group of 52 people here https://tinyurl.com/letter-signed-52-people - as well as individually - I did my darnest to encourage them to do a standard. There's also the National Academy of Public Administration which is probably the latest remaining non-partisan forum for discussions like this too. On Mon, Oct 9, 2023 at 7:46=E2=80=AFPM Vint Cerf = wrote: 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 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 crazy 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 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 then, 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 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 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 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? On Sat, Oct 7, 2023 at 4:10=E2=80=AFPM Jack Haverty wrote: 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 charge 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?=20 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 "register" as a commenter and then submit their (latest only) comment into the melee. 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 issues 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, would 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 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" 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 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 third party submitting multiple comments for their clients (or "clients") 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 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 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 resources 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're 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, we must foster a proactive, 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. 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. 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 wanting 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 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 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 co-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 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-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 wrote: =20 =20 Thanks for all your efforts to keep the "feedback loop" to =20 the rulemakers functioning! =20 =20 I'd like to offer a suggestion for a hopefully politically =20 acceptable way to handle the deluge, derived from my own battles with "email" over the years (decades). =20 =20 Back in the 1970s, I implemented one of the first email =20 systems on the Arpanet, under the mentorship of JCR Licklider, who had been pursuing his 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, protected by passwords, in order to legitimately use the network. The mechanisms were crude and easily broken, but the principle applied. =20 =20 Over the years, that principle has been forgotten, and the =20 right to be anonymous has become entrenched. But many 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. 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. 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. =20 =20 So, my suggestion for handling the deluge of "comments" is: =20 =20 1/ create some mechanism for "registering" your intent to =20 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 identifying their users. =20 =20 2/ Also make registration optional - anyone can still submit =20 comments anonymously if they choose. =20 =20 3/ for "registered commenters", provide a way to "edit" your =20 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, which will be the last one you submit. =20 =20 4/ In the thousands of pages of comments, somehow flag the =20 ones that are 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. =20 =20 This may not reduce the deluge of comments, but I'd expect =20 it to help the lawyers and politicians keep their heads above the water. =20 =20 Anonymity is an important issue for Net Neutrality too, but =20 ------=_NextPart_000_0266_01D9FB76.BFC93E90 Content-Type: text/html; charset="UTF-8" Content-Transfer-Encoding: quoted-printable

 

 


From: = Nnagain [mailto:nnagain-bounces@lists.bufferbloat.net] On Behalf Of Robert McMahon via Nnagain
Sent: Tuesday, October = 10, 2023 12:01 PM
To: Jack Haverty via = Nnagain
Cc: Robert McMahon
Subject: Re: [NNagain] = somewhat OT: Licklidder

 

Thanks for = sharing. It's amazing to me what was accomplished and continues forward with = communications & compute by extremely phenomenal people. I think the closest analog = is the Gutenberg press, which many know had profound effects on the human = condition. A hope is that we figure out how to progress in a similar manner, and = somehow, the diffusion of knowledge and peaceful coexistence prevail.

Johann = Gutenberg=E2=80=99s invention of movable-type printing quickened the spread of knowledge, discoveries, and literacy in Renaissance Europe. The printing revolution = also contributed mightily to the Protestant Reformation that split apart the Catholic Church.

[RR] It is claimed by many to be the achievement that most profoundly affected humanity over the last two = millennia! Hard to disagree IMO!

Cheers,<= /b>

RR



Bob

On Oct 10, 2023, at 10:12 AM, Jack Haverty via Nnagain <nnagain@lists.bufferbloat.net> wrote:

FYI, The Arpanet was a key player in that =
patent fight.  The Arpanet 
IMPs (the packet switches) downloaded software from each other, and that =
capability was used to distribute new releases of the IMP program.  = I
suggested that 1970s implementation to the lawyers as a good example of =
prior art, which led to a lot of work that eventually resurrected the =
1970s IMP code from a moldy listing in someone's basement, and got it =
running again on simulated ancient hardware.   At one point = the 4-node
Arpanet of 1970 was created and run, in anticipation of a demo of prior =
art at trial.  Sadly (for me at least) the combatants suddenly = settled
out of court, so the trial never happened and the patent issue was not =
adjudicated.   But the resurrected IMP code is on github now, = so anyone
interested can run their own Arpanet.

Jack


On 10/10/23 08:53, Steve Crocker via Nnagain = wrote:
 Lots of good stuff here and I missed the =
earlier posts, but one small 
=C2=A0thing caught my = attention:
 About 10 years =
ago, I accidentally got involved in a =
patent
=C2=A0=C2=A0=C2=A0=C2=A0 dispute to be an =
"expert witness", for a patent involving
=C2=A0=C2=A0=C2=A0=C2=A0 downloading new programs over a communications = path into a remote
=C2=A0=C2=A0=C2=A0=C2=A0 computer (yes, what all our devices do almost = every day).

=C2=A0In the seminal period of late 1968 and early 1969 when we were =
=C2=A0thinking about Arpanet protocols, one idea that was very much part = of
=C2=A0our thinking was downloading a small program at the beginning of = an
=C2=A0interactive session.  The downloaded program would take care = of local
=C2=A0interactions to avoid the need to send every character across the = net
=C2=A0only to have it echoed remotely.  Why not always use local = echo? 
=C2=A0Because most of the time-shared systems in the various = ARPA-supported
=C2=A0research environments had distinct ways of interpreting each and =
=C2=A0every character.  Imposing a network-wide rule of local = echoing would
=C2=A0have compromised the usability of most of the systems on the = Arpanet. 
=C2=A0I think Multics was the only "modern" line-at-a-time = system at the time.

=C2=A0In March 1969 we decided it was time to write down the ideas from = our
=C2=A0meetings in late 1968 and early 1969.  The first batch of = RFCs
=C2=A0included Rulifson's RFC 5.  He proposed DEL, the Decode-Encode
=C2=A0Language.  Elie's RFC 51 a year later proposed the Network = Interchange
=C2=A0Language.  In both cases the basic concept was the creation = of a
=C2=A0simple language, easily implementable on each platform, that would =
=C2=A0mediate the interaction with a remote system.  The programs = were
=C2=A0expected to be short -- hence downloadable quickly -- and either =
=C2=A0interpreted or quickly translated.  There was a tiny bit of =
=C2=A0experimental work along this line, but it was far ahead of its = time. 
=C2=A0I think it was about 25 years before ActiveX came along, followed = by Java.

=C2=A0Steve


=C2=A0On Tue, Oct 10, 2023 at 11:30
=E2=80=AFAM Dave Taht via = Nnagain
=C2=A0<nnagain@lists.bufferbloat.net> wrote:

=C2=A0=C2=A0=C2=A0=C2=A0 On Mon, Oct 9, 2023 at 7:56=E2=80=AFPM Jack Haverty via Nnagain
=C2=A0=C2=A0=C2=A0=C2=A0 <nnagain@lists.bufferbloat.net> = wrote:

=C2=A0=C2=A0=C2=A0=C2=A0 For starters it is an honor to be conversing = with folk that knew Bob
=C2=A0=C2=A0=C2=A0=C2=A0 Taylor, and "Lick", and = y'all made me go back and re-read

=C2=A0=C2=A0=C2=A0=C2=A0 http://memex.org/licklider.pdf

=C2=A0=C2=A0=C2=A0=C2=A0 For inspiration. I think everyone in our field = should re-read that,
=C2=A0=C2=A0=C2=A0=C2=A0 periodically. For example he makes an = overgeneralization about the
=C2=A0=C2=A0=C2=A0=C2=A0 thinking processes of men, as compared to the = computers of the time,
=C2=A0=C2=A0=C2=A0=C2=A0 and not to women...

=C2=A0=C2=A0=C2=A0=C2=A0 But I have always had an odd question - what = songs did Lick play on
=C2=A0=C2=A0=C2=A0=C2=A0 guitar? Do any recordings exist?

=C2=A0=C2=A0=C2=A0=C2=A0 Music defines who I am, at least. I love the = angularness and surprises
=C2=A0=C2=A0=C2=A0=C2=A0 in jazz, and the deep storytelling buried deep = in Shostakovich's
=C2=A0=C2=A0=C2=A0=C2=A0 Fifth. Moving forward to modern music: the = steady backbeat of Burning
=C2=A0=C2=A0=C2=A0=C2=A0 Man - and endless repetition of short phrases - = seems to lead to
=C2=A0=C2=A0=C2=A0=C2=A0 groupthink - I can hardly stand EDM for an = hour.

=C2=A0=C2=A0=C2=A0=C2=A0  I am "maked" by Angela' = Lansbury's Sweeny Todd, and my religion,
=C2=A0=C2=A0=C2=A0=C2=A0 forever reformed by Monty Python's Life of = Brian, One Flew over the
=C2=A0=C2=A0=C2=A0=C2=A0 Cookoos nest, 12 Angry Men, and the 12 Monkees, = Pink Floyd and punk
=C2=A0=C2=A0=C2=A0=C2=A0 music were the things that shaped me. No doubt = it differs
=C2=A0=C2=A0=C2=A0=C2=A0 significantly for everyone here, please = share?

=C2=A0=C2=A0=C2=A0=C2=A0 Powerful tales and their technologies predate = the internet, and
=C2=A0=C2=A0=C2=A0=C2=A0 because they were wildly shared, influenced how = generations thought
=C2=A0=C2=A0=C2=A0=C2=A0 without being the one true answer. Broadcast = media, also, was joint,
=C2=A0=C2=A0=C2=A0=C2=A0 and in school we

=C2=A0=C2=A0=C2=A0=C2=A0 We are in a new era of uncommonality of = experience, in part from
=C2=A0=C2=A0=C2=A0=C2=A0 bringing in all the information in the world, = while still separated by
=C2=A0=C2=A0=C2=A0=C2=A0 differences in language, exposure, education, = and culture, although
=C2=A0=C2=A0=C2=A0=C2=A0 nowadays it has become so easy and natural to = be able to use computer
=C2=A0=C2=A0=C2=A0=C2=A0 assisted language translation tools, I do not = know how well they truly
=C2=A0=C2=A0=C2=A0=C2=A0 make the jump between cultures.

=C2=A0=C2=A0=C2=A0=C2=A0 In that paper he talked about 75% of his time = being spent setting up
=C2=A0=C2=A0=C2=A0=C2=A0 to do analytics, where today so much = information exists as to be
=C2=A0=C2=A0=C2=A0=C2=A0 impossible to analyze.

=C2=A0=C2=A0=C2=A0=C2=A0 I only have a few more small comments below, = but I wanted to pick out
=C2=A0=C2=A0=C2=A0=C2=A0 the concepts of TOS and backpressure as needing = thought on another
=C2=A0=C2=A0=C2=A0=C2=A0 day, in another email (what was licks song = list??? :)). The internet
=C2=A0=C2=A0=C2=A0=C2=A0 has very little Tos or backpressure, and Flow = Queuing based algorithms
=C2=A0=C2=A0=C2=A0=C2=A0 actually function thusly:

=C2=A0=C2=A0=C2=A0=C2=A0 If the arrival rate of a flow is less than the = departure rate of all
=C2=A0=C2=A0=C2=A0=C2=A0 other flows, it goes out first.

=C2=A0=C2=A0=C2=A0=C2=A0 To some extent this matches some of Nagles' = "every application has a
=C2=A0=C2=A0=C2=A0=C2=A0 right to one packet in the network", and = puts a reward into the system
=C2=A0=C2=A0=C2=A0=C2=A0 for applications that use slightly less than = their fair share of the
=C2=A0=C2=A0=C2=A0=C2=A0 bandwidth.
 IMHO, the problem may be that the Internet, =
and computing
=C2=A0=C2=A0=C2=A0=C2=A0 technology in =
general, is so new that non-technical organizations,
=C2=A0=C2=A0=C2=A0=C2=A0 such as government entities, don't understand = it and therefore
=C2=A0=C2=A0=C2=A0=C2=A0 can't figure out whether or how to regulate = anything involved.

=C2=A0In other, older, "technologies", rules, procedures, = and
=C2=A0=C2=A0=C2=A0=C2=A0 traditions have =
developed over the years to provide for feedback
=C2=A0=C2=A0=C2=A0=C2=A0 and control between governees and = governors.  Roberts Rules of
=C2=A0=C2=A0=C2=A0=C2=A0 Order was created 150 years ago, and is still = widely used to
=C2=A0=C2=A0=C2=A0=C2=A0 manage public meetings.  I've been in = local meetings where
=C2=A0=C2=A0=C2=A0=C2=A0 everyone gets a chance to speak, but are = limited to a few minutes
=C2=A0=C2=A0=C2=A0=C2=A0 to say whatever's on their mind.  You have = to appear in person,
=C2=A0=C2=A0=C2=A0=C2=A0 wait your turn, and make your comment. Doing so = is free, but still
=C2=A0=C2=A0=C2=A0=C2=A0 has the cost of time and hassle to get to the = meeting.

=C2=A0Organizations have figured out over the years how to = manage
=C2=A0=C2=A0=C2=A0=C2=A0 meetings.  =
[Vint - remember the "Rathole!" mechanism that we used
=C2=A0=C2=A0=C2=A0=C2=A0 to keep Internet meetings on track...?]

=C2=A0=C2=A0=C2=A0=C2=A0 PARC had = "Dealer".
 From =
what David describes, it sounds like the current =
"public
=C2=A0=C2=A0=C2=A0=C2=A0 comment" =
mechanisms in the electronic arena are only at the stage
=C2=A0=C2=A0=C2=A0=C2=A0 where the loudest voices can drown out all = others, and public
=C2=A0=C2=A0=C2=A0=C2=A0 debates are essentially useless cacophonies of = the loudest
=C2=A0=C2=A0=C2=A0=C2=A0 proponents of the various viewpoints.  =  There are no rules.   Why
=C2=A0=C2=A0=C2=A0=C2=A0 should anyone submit their own sensible = comments, knowing they'll
=C2=A0=C2=A0=C2=A0=C2=A0 be lost in the = noise?

=C2=A0In non-electronic public forums, such behavior is ruled out, = and
=C2=A0=C2=A0=C2=A0=C2=A0 if it persists, the =
governing body can have offenders ejected,
=C2=A0=C2=A0=C2=A0=C2=A0 adjourn a meeting until cooler heads prevail, = or otherwise make
=C2=A0=C2=A0=C2=A0=C2=A0 the discourse useful for informing decisions. =  Courts can issue
=C2=A0=C2=A0=C2=A0=C2=A0 restraining orders, but has any court ever = issued such an order
=C2=A0=C2=A0=C2=A0=C2=A0 applying to an electronic = forum?

=C2=A0So, why haven't organizations yet developed rules and = mechanisms
=C2=A0=C2=A0=C2=A0=C2=A0 for managing =
electronic discussions....?

=C2=A0I'd offer two observations and suggestions.

=C2=A0-----

=C2=A0First, a major reason for a lack of such rules and = mechanisms
=C2=A0=C2=A0=C2=A0=C2=A0 may be an =
educational gap.  Administrators, politicians, and
=C2=A0=C2=A0=C2=A0=C2=A0 staffers may simply not understand all this = newfangled technology,
=C2=A0=C2=A0=C2=A0=C2=A0 or how it works, and are drowning in a sea of = terminology,
=C2=A0=C2=A0=C2=A0=C2=A0 acronyms, and concepts that make no sense (to = them).   In the FCC
=C2=A0=C2=A0=C2=A0=C2=A0 case, even the technical gurus may have deep = knowledge of their
=C2=A0=C2=A0=C2=A0=C2=A0 traditional realm of telephony, radio, and = related issues and
=C2=A0=C2=A0=C2=A0=C2=A0 policy tradeoffs.   But they may be = largely ignorant of computing
=C2=A0=C2=A0=C2=A0=C2=A0 and networking equivalents.  Probably even = worse, they may
=C2=A0=C2=A0=C2=A0=C2=A0 unconsciously consider the new world as a = simple evolution of the
=C2=A0=C2=A0=C2=A0=C2=A0 old, not recognizing the impact of incredibly = fast computers and
=C2=A0=C2=A0=C2=A0=C2=A0 communications, and the advances that they = enable, such as "AI" -
=C2=A0=C2=A0=C2=A0=C2=A0 whatever that = is...

=C2=A0About 10 years ago, I accidentally got involved in a = patent
=C2=A0=C2=A0=C2=A0=C2=A0 dispute to be an =
"expert witness", for a patent involving
=C2=A0=C2=A0=C2=A0=C2=A0 downloading new programs over a communications = path into a remote
=C2=A0=C2=A0=C2=A0=C2=A0 computer (yes, what all our devices do almost = every day).   I was
=C2=A0=C2=A0=C2=A0=C2=A0 astounded when I learned how little the = "judicial system"
=C2=A0=C2=A0=C2=A0=C2=A0 (lawyers, judges, legislators, etc.) knew about = computer and
=C2=A0=C2=A0=C2=A0=C2=A0 network technology.   That didn't = stop them from debating the
=C2=A0=C2=A0=C2=A0=C2=A0 meaning of technical terms.  What is RAM? = How does "programming"
=C2=A0=C2=A0=C2=A0=C2=A0 differ from "reprogramming"?  = What is "memory"?  What is a
=C2=A0=C2=A0=C2=A0=C2=A0 "processor"?   What is an = "operating system"?   The arguments
=C2=A0=C2=A0=C2=A0=C2=A0 continue until eventually a judge declares what = the answer is,
=C2=A0=C2=A0=C2=A0=C2=A0 with little technical knowledge or expertise to = help.   So you can
=C2=A0=C2=A0=C2=A0=C2=A0 easily get legally binding definitions such as = "operating system"
=C2=A0=C2=A0=C2=A0=C2=A0 means "Windows", and that all = computers contain an operating = system.

=C2=A0I spent hours on the phone over about 18 months, explaining = to
=C2=A0=C2=A0=C2=A0=C2=A0 the lawyers how =
computers and networks actually worked.   In turn,
=C2=A0=C2=A0=C2=A0=C2=A0 they taught me quite a lot about the vagaries = of the laws and
=C2=A0=C2=A0=C2=A0=C2=A0 patents.  It was fascinating but also = disturbing to see how
=C2=A0=C2=A0=C2=A0=C2=A0 ill-prepared the legal system was for new = technologies.

=C2=A0So, my suggestion is that a focus be placed on helping = the
=C2=A0=C2=A0=C2=A0=C2=A0 non-technical =
decision makers understand the nuances of computing
=C2=A0=C2=A0=C2=A0=C2=A0 and the Internet.  I don't think that will = be successful by
=C2=A0=C2=A0=C2=A0=C2=A0 burying them in the sea of technical jargon and = acronyms.

=C2=A0Before I retired, I spent a lot of time with C-suite = denizens
=C2=A0=C2=A0=C2=A0=C2=A0 from companies =
outside of the technology industry - banks,
=C2=A0=C2=A0=C2=A0=C2=A0 manufacturers, transportation, etc. - helping = them understand what
=C2=A0=C2=A0=C2=A0=C2=A0 "The Internet" was, and help them see = it as both a huge
=C2=A0=C2=A0=C2=A0=C2=A0 opportunity and a huge threat to their = businesses.  One technique
=C2=A0=C2=A0=C2=A0=C2=A0 I used was simply stolen from the early days of = The Internet.

=C2=A0When we were involved in designing the internal mechanisms = of
=C2=A0=C2=A0=C2=A0=C2=A0 the Internet, in =
particular TCPV4, we didn't know much about
=C2=A0=C2=A0=C2=A0=C2=A0 networks either.  So we used = analogies.  In particular we used the
=C2=A0=C2=A0=C2=A0=C2=A0 existing transportation infrastructure as a = model.   Moving bits
=C2=A0=C2=A0=C2=A0=C2=A0 around the world isn't all that different from = moving goods and
=C2=A0=C2=A0=C2=A0=C2=A0 people.   But everyone, even with no = technical expertise, knows
=C2=A0=C2=A0=C2=A0=C2=A0 about = transportation.

=C2=A0It turns out that there are a lot of useful analogies. = For
=C2=A0=C2=A0=C2=A0 =C2=A0example, we =
recognized that there were different kinds of
=C2=A0=C2=A0=C2=A0=C2=A0 "traffic" with different needs.  = Coal for power plants was
=C2=A0=C2=A0=C2=A0=C2=A0 important, but not urgent.  If a coal = train waits on a siding
=C2=A0=C2=A0=C2=A0=C2=A0 while a passenger train passes, it's OK, even = preferred.  There
=C2=A0=C2=A0=C2=A0=C2=A0 could be different "types of service" = available from the
=C2=A0=C2=A0=C2=A0=C2=A0 transportation infrastructure.   At = the time (late 1970s) we
=C2=A0=C2=A0=C2=A0=C2=A0 didn't know exactly how to do that, but decided = to put a field in
=C2=A0=C2=A0=C2=A0=C2=A0 the IP header as a placeholder - the = "TOS" field. Figuring out
=C2=A0=C2=A0=C2=A0=C2=A0 what different TOSes there should be, and how = they would be
=C2=A0=C2=A0=C2=A0=C2=A0 handled differently, was still on the to-do = list.   There are even
=C2=A0=C2=A0=C2=A0=C2=A0 analogies to the Internet - goods might travel = over a "marine
=C2=A0=C2=A0=C2=A0=C2=A0 network" to a "port", where they = are moved onto a "rail network",
=C2=A0=C2=A0=C2=A0=C2=A0 to a distributor, and moved on the highway = network to their final
=C2=A0=C2=A0=C2=A0=C2=A0 destination.  Routers, gateways, = ...

=C2=A0Other transportation analogies reinforced the notion of = TOS. 
=C2=A0=C2=A0=C2=A0=C2=A0 E.g., if you're =
sending a document somewhere, you can choose how
=C2=A0=C2=A0=C2=A0=C2=A0 to send it - normal postal mail, or Priority = Mail, or even use a
=C2=A0=C2=A0=C2=A0=C2=A0 different "network" such as an = overnight delivery service. 
=C2=A0=C2=A0=C2=A0=C2=A0 Different TOS would engage different behaviors = of the underlying
=C2=A0=C2=A0=C2=A0=C2=A0 communications system, and might also have = different costs to use
=C2=A0=C2=A0=C2=A0=C2=A0 them.  Sending a ton of coal to get = delivered in a week or two
=C2=A0=C2=A0=C2=A0=C2=A0 would cost a lot less than sending a ton of = documents for
=C2=A0=C2=A0=C2=A0=C2=A0 overnight = delivery.

=C2=A0There were other transportation analogies heard during the = TCPV4
=C2=A0=C2=A0=C2=A0=C2=A0 design discussions - =
e.g., "Expressway Routing" (do you take a
=C2=A0=C2=A0=C2=A0=C2=A0 direct route over local streets, or go to the = freeway even though
=C2=A0=C2=A0=C2=A0=C2=A0 it's longer) and "Multi-Homing" (your = manufacturing plant has
=C2=A0=C2=A0=C2=A0=C2=A0 access to both a highway and a rail = line).

=C2=A0Suggestion -- I suspect that using a familiar = infrastructure
=C2=A0=C2=A0=C2=A0=C2=A0 such as transport to =
discuss issues with non-technical decision
=C2=A0=C2=A0=C2=A0=C2=A0 makers would be helpful.  E.g., imagine = what would happen if some
=C2=A0=C2=A0=C2=A0=C2=A0 particular "net neutrality" set of = rules was placed on the
=C2=A0=C2=A0=C2=A0=C2=A0 transportation infrastructure?  =  Would it have a desirable = effect?

=C2=A0-----

=C2=A0Second, in addition to anonymity as an important issue in = the
=C2=A0=C2=A0=C2=A0=C2=A0 electronic world, my =
experience as a mentee of Licklider surfaced
=C2=A0=C2=A0=C2=A0=C2=A0 another important issue in the "galactic = network" vision -- "Back
=C2=A0=C2=A0=C2=A0=C2=A0 Pressure".     The notion = is based in existing knowledge. 
=C2=A0=C2=A0=C2=A0=C2=A0  Economics has notions of Supply and = Demand and Cost Curves. 
=C2=A0=C2=A0=C2=A0=C2=A0  Engineering has the notion of = "Negative Feedback" to stabilize
=C2=A0=C2=A0=C2=A0=C2=A0 mechanical, electrical, or other = systems.

=C2=A0We discussed Back Pressure, in the mid 70s, in the context = of
=C2=A0=C2=A0=C2=A0=C2=A0 electronic mail, and =
tried to get the notion of "stamps" accepted
=C2=A0=C2=A0=C2=A0=C2=A0 as part of the email mechanisms.  The = basic idea was that there
=C2=A0=C2=A0=C2=A0=C2=A0 had to be some form of "back = pressure" to prevent overload by
=C2=A0=C2=A0=C2=A0=C2=A0 discouraging sending of huge quantities of = mail.

=C2=A0At the time, mail traffic was light, since every message = was
=C2=A0=C2=A0=C2=A0=C2=A0 typed by hand by =
some user.  In Lick's group we had experimented
=C2=A0=C2=A0=C2=A0=C2=A0 with using email as a way for computer programs = to interact.  In
=C2=A0=C2=A0=C2=A0=C2=A0 Lick's vision, humans would interact by using = their computers as
=C2=A0=C2=A0=C2=A0=C2=A0 their agents.   Even then, computers = could send email a lot faster
=C2=A0=C2=A0=C2=A0=C2=A0 and continuously than any human at a keyboard, = and could easily
=C2=A0=C2=A0=C2=A0=C2=A0 flood the network.  [This epiphany = occurred shortly after a
=C2=A0=C2=A0=C2=A0=C2=A0 mistake in configuring distribution lists = caused so many messages
=C2=A0=C2=A0=C2=A0=C2=A0 and replies that our machine crashed as its = disk space ran out.]

=C2=A0"Stamps" didn't necessarily represent monetary cost. = Back
=C2=A0=C2=A0=C2=A0=C2=A0 pressure could be =
simple constraints, e.g., no user can send more
=C2=A0=C2=A0=C2=A0=C2=A0 than 500 (or whatever) messages per day.  =  This notion never got
=C2=A0=C2=A0=C2=A0=C2=A0 enough support to become part of the email = standards; I still
=C2=A0=C2=A0=C2=A0=C2=A0 think it would help with the deluge of spam we = all experience today.

=C2=A0Back Pressure in the Internet today is largely non-existent.  = I
=C2=A0=C2=A0=C2=A0=C2=A0 (or my AI and =
computers) can send as much email as I like. 
=C2=A0=C2=A0=C2=A0=C2=A0  Communications carriers promote = "unlimited data" but won't
=C2=A0=C2=A0=C2=A0=C2=A0 guarantee anything.   Memory has = become cheap, and as a result
=C2=A0=C2=A0=C2=A0=C2=A0 behaviors such as "buffer bloat" have = appeared.

=C2=A0Suggestion - educate the decision-makers about Back = Pressure,
=C2=A0=C2=A0=C2=A0=C2=A0 using highway =
analogies (metering lights, =
etc.)

=C2=A0-----

=C2=A0Education about the new technology, but by using some = familiar
=C2=A0=C2=A0=C2=A0=C2=A0 analogs, and =
introduction of Back Pressure, in some appropriate
=C2=A0=C2=A0=C2=A0=C2=A0 form, as part of a "network = neutrality" policy, would be the two
=C2=A0=C2=A0=C2=A0=C2=A0 foci I'd = recommend.

=C2=A0My prior suggestion of "registration" and accepting only = the
=C2=A0=C2=A0=C2=A0=C2=A0 last comment was =
based on the observations above.  Back pressure
=C2=A0=C2=A0=C2=A0=C2=A0 doesn't have to be monetary, and registered = users don't have to be
=C2=A0=C2=A0=C2=A0=C2=A0 personally identified.   Simply = making it sufficiently "hard" to
=C2=A0=C2=A0=C2=A0=C2=A0 register (using CAPTCHAs, 2FA, whatever) would = be a "cost"
=C2=A0=C2=A0=C2=A0=C2=A0 discouraging "loud voices".  =  Even the law firms submitting
=C2=A0=C2=A0=C2=A0=C2=A0 millions of comments on behalf of their clients = might balk at the
=C2=A0=C2=A0=C2=A0=C2=A0 cost (in labor not money) to register their = million clients, even
=C2=A0=C2=A0=C2=A0=C2=A0 anonymously, so each could get his/her comment = submitted.   Of
=C2=A0=C2=A0=C2=A0=C2=A0 course, they could always pass the costs on to = their (million?
=C2=A0=C2=A0=C2=A0=C2=A0 really?) clients. But it would still be Back = Pressure.

=C2=A0One possibility -- make the "cost" of submitting a = million
=C2=A0=C2=A0=C2=A0=C2=A0 electronic comments =
equal to the cost of submitting a million
=C2=A0=C2=A0=C2=A0=C2=A0 = postcards...?

=C2=A0Jack Haverty


=C2=A0On 10/9/23 16:55, David Bray, PhD wrote:

=C2=A0Great points Vint as you're absolutely right - there = are
=C2=A0=C2=A0=C2=A0=C2=A0 multiple modalities =
here (and in the past it was spam from
=C2=A0=C2=A0=C2=A0=C2=A0 thousands of postcards, then mimeographs, then = faxes, etc.)

=C2=A0The standard historically has been set by the = Administrative
=C2=A0=C2=A0=C2=A0=C2=A0 Conference of the =
United =
States: https://www.acus.gov/about-acus<=
/a>

=C2=A0In 2020 there seemed to be an effort to gave the = General
=C2=A0=C2=A0=C2=A0=C2=A0 Services =
Administration weigh-in, however they closed that
=C2=A0=C2=A0=C2=A0=C2=A0 rulemaking attempt without publishing any of = the comments they got
=C2=A0=C2=A0=C2=A0=C2=A0 and no announcement why it was = closed.

=C2=A0As for what part of Congress - I believe ACUS was championed = by
=C2=A0=C2=A0=C2=A0=C2=A0 both the Senate and =
House Judiciary Committees as it has oversight
=C2=A0=C2=A0=C2=A0=C2=A0 and responsibility for the interpretations of = the Administrative
=C2=A0=C2=A0=C2=A0=C2=A0 Procedure Act of 1946 (which sets out the whole = rulemaking procedure).

=C2=A0Sadly there isn't a standard across agencies - which also = means
=C2=A0=C2=A0=C2=A0=C2=A0 there isn't a =
standard across Administrations. Back in 2018 and
=C2=A0=C2=A0=C2=A0=C2=A0 2020, both with this group of 52 people = here
=C2=A0=C2=A0=C2=A0=C2=A0
https://tinyurl.com/= letter-signed-52-people - as well as
=C2=A0=C2=A0=C2=A0=C2=A0 individually - I did my darnest to encourage = them to do a standard.

=C2=A0There's also the National Academy of Public Administration = which
=C2=A0=C2=A0=C2=A0=C2=A0 is probably the =
latest remaining non-partisan forum for
=C2=A0=C2=A0=C2=A0=C2=A0 discussions like this = too.


=C2=A0On Mon, Oct 9, 2023 at 7:46
=E2=80=AFPM Vint Cerf = <vint@google.com> = wrote:

=C2=A0David, this is a good list.
=C2=A0FACA has rules for public participation, for example.

=C2=A0I think it should be taken into account for any = public
=C2=A0=C2=A0=C2=A0=C2=A0 commenting process =
that online (and offline such as USPS or fax
=C2=A0=C2=A0=C2=A0=C2=A0 and phone calls) that spam and artificial = inflation of comments
=C2=A0=C2=A0=C2=A0=C2=A0 are possible. Is there any specific standard = for US = agency public
=C2=A0=C2=A0=C2=A0=C2=A0 comment handling? If now, what committees of = the US Congress might
=C2=A0=C2=A0=C2=A0=C2=A0 have = jurisdiction?

=C2=A0v


=C2=A0On Tue, Oct 10, 2023 at 8:22
=E2=80=AFAM David Bray, PhD = via Nnagain
=C2=A0=C2=A0=C2=A0=C2=A0 =
<nnagain@lists.bufferbloat.net> =
wrote:

=C2=A0I'm all for doing new things to make things better.

=C2=A0At the same time, I used to do bioterrorism preparedness = and
=C2=A0=C2=A0=C2=A0=C2=A0 response from =
2000-2005 (and aside from asking myself what kind of
=C2=A0=C2=A0=C2=A0=C2=A0 crazy world needed counter-bioterrorism = efforts... I also realized
=C2=A0=C2=A0=C2=A0=C2=A0 you don't want to interject something = completely new in the middle
=C2=A0=C2=A0=C2=A0=C2=A0 of an unfolding crisis event). If something = were to be injected
=C2=A0=C2=A0=C2=A0=C2=A0 now, it would have to have consensus from both = sides, otherwise at
=C2=A0=C2=A0=C2=A0=C2=A0 least one side (potentially detractors from = both) will claim that
=C2=A0=C2=A0 =C2=A0=C2=A0whatever form the new approaches take are = somehow advantaging "the
=C2=A0=C2=A0=C2=A0=C2=A0 other side" and disadvantaging = them.

=C2=A0Probably would take a ruling by the Administrative = Conference
=C2=A0=C2=A0=C2=A0=C2=A0 of the =
United =
States, at a minimum to answer these =
five questions
=C2=A0=C2=A0=C2=A0=C2=A0 - and even then, introducing something = completely different in the
=C2=A0=C2=A0=C2=A0=C2=A0 midst of a political melee might just invite = mudslinging unless
=C2=A0=C2=A0=C2=A0=C2=A0 moderate voices on both sides can reach some = consensus.

=C2=A01. Does identity matter regarding who files a comment or not = =E2=80=94
=C2=A0=C2=A0=C2=A0=C2=A0 and must one be a =
U.S. =
person in order to file?

=C2=A02. Should agencies publish real-time counts of the number = of
=C2=A0=C2=A0=C2=A0=C2=A0 comments received =
=E2=80=94 or is it better to wait until the end of a
=C2=A0=C2=A0=C2=A0=C2=A0 commenting round to make all comments = available, including counts?

=C2=A03. Should third-party groups be able to file on behalf = of
=C2=A0=C2=A0=C2=A0=C2=A0 someone else or not =
=E2=80=94 and do agencies have the right to remove
=C2=A0=C2=A0=C2=A0=C2=A0 spam-like = comments?

=C2=A04. Should the public commenting process permit = multiple
=C2=A0=C2=A0=C2=A0=C2=A0 comments per =
individual for a proceeding =E2=80=94 and if so, how many
=C2=A0=C2=A0=C2=A0=C2=A0 comments from a single individual are too many? = 100? 1000? More?

=C2=A05. Finally, should the U.S. government itself = consider, given
=C2=A0=C2=A0=C2=A0=C2=A0 public perceptions =
about potential conflicts of interest for any
=C2=A0=C2=A0=C2=A0=C2=A0 agency performing a public commenting process, = whether it would be
=C2=A0=C2=A0=C2=A0=C2=A0 better to have third-party groups take = responsibility for
=C2=A0=C2=A0=C2=A0=C2=A0 assembling comments and then filing those = comments via a validated
=C2=A0=C2=A0=C2=A0=C2=A0 process with the = government?



=C2=A0On Sat, Oct 7, 2023 at 4:10
=E2=80=AFPM Jack Haverty = <jack@3kitty.org>
=C2=A0=C2=A0=C2=A0=C2=A0 =
wrote:

=C2=A0Hi again David et al,

=C2=A0Interesting frenzy...lots of questions that need answers = and
=C2=A0=C2=A0=C2=A0=C2=A0 associated =
policies.   I served 6 years as an elected official (in
=C2=A0=C2=A0=C2=A0=C2=A0 a small special district in California), = so I have some small
=C2=A0=C2=A0=C2=A0=C2=A0 understanding of the government side of things = and the constraints
=C2=A0=C2=A0=C2=A0=C2=A0 involved.   Being in charge doesn't = mean you can do what you want.

=C2=A0I'm thinking here more near-term and incremental steps.  = You
=C2=A0=C2=A0=C2=A0=C2=A0 said "These =
same questions need pragmatic pilots that involve the
=C2=A0=C2=A0=C2=A0=C2=A0 public ..."

=C2=A0So, how about using the current NN situation for a = pilot? 
=C2=A0=C2=A0=C2=A0=C2=A0 Keep all the current =
ways and emerging AI techniques to continue
=C2=A0=C2=A0=C2=A0=C2=A0 to flood the system with comments.  But = also offer an *optional*
=C2=A0=C2=A0=C2=A0=C2=A0 way for humans to "register" as a = commenter and then submit their
=C2=A0=C2=A0=C2=A0=C2=A0 (latest only) comment into the melee.  = Will people use it?  Will
=C2=A0=C2=A0=C2=A0=C2=A0 "consumers" (the lawyers, = commissioners, etc.) find it useful?

=C2=A0I've found it curious, for decades now, that there are = (too
=C2=A0=C2=A0=C2=A0=C2=A0 many) mechanisms for =
"secure email", that may help with the flood
=C2=A0=C2=A0=C2=A0=C2=A0 of disinformation from anonymous senders, but = very very few people
=C2=A0=C2=A0=C2=A0=C2=A0 use them.   Maybe they don't know = how; maybe the available schemes
=C2=A0=C2=A0=C2=A0=C2=A0 are too flawed; maybe = ...?

=C2=A0About 30 years ago, I was a speaker in a public = meeting
=C2=A0=C2=A0=C2=A0=C2=A0 orchestrated by =
USPS, and recommended that they take a lead role,
=C2=A0=C2=A0=C2=A0=C2=A0 e.g., by acting as a national CA - certificate = authority.  Never
=C2=A0=C2=A0=C2=A0=C2=A0 happened though.   FCC issues lots of = licenses...perhaps they
=C2=A0=C2=A0=C2=A0=C2=A0 could issue online credentials = too?

=C2=A0Perhaps a "pilot" where you will also accept comments = by
=C2=A0=C2=A0=C2=A0=C2=A0 email, some possibly =
sent by "verified" humans if they understand
=C2=A0=C2=A0=C2=A0=C2=A0 how to do so, would be worth trying?  =  Perhaps comments on
=C2=A0=C2=A0=C2=A0=C2=A0 "technical aspects" coming from = people who demonstrably know how
=C2=A0=C2=A0=C2=A0=C2=A0 to use technology would be valuable to the = policy makers?

=C2=A0The Internet, and technology such as TCP, began as = an
=C2=A0=C2=A0=C2=A0=C2=A0 experimental pilot =
about 50 years ago.  Sometimes pilots become
=C2=A0=C2=A0=C2=A0=C2=A0 infrastructures.

=C2=A0FYI, I'm signing this message.  Using OpenPGP.  I = could
=C2=A0=C2=A0=C2=A0=C2=A0 encrypt it also, but =
my email program can't find your public =
key.

=C2=A0Jack Haverty


=C2=A0On 10/5/23 14:21, David Bray, PhD wrote:

=C2=A0Indeed Jack - a few things to balance - the = Administrative
=C2=A0=C2=A0=C2=A0=C2=A0 Procedure Act of =
1946 (on which the idea of rulemaking is based)
=C2=A0=C2=A0=C2=A0=C2=A0 us about raising legal concerns that must be = answered by the
=C2=A0=C2=A0=C2=A0=C2=A0 agency at the time the rulemaking is done. It's = not a vote nor is
=C2=A0 =C2=A0=C2=A0=C2=A0it the case that if the agency gets tons of = comments in one
=C2=A0=C2=A0=C2=A0=C2=A0 direction that they have to go in that = direction. Instead it's
=C2=A0=C2=A0=C2=A0=C2=A0 only about making sure legal concerns are = considered and responded
=C2=A0=C2=A0=C2=A0=C2=A0 to before the agency before the agency acts. = (Which is partly why
=C2=A0=C2=A0=C2=A0=C2=A0 sending "I'm for XYZ" or "I'm = against ABC" really doesn't mean
=C2=A0=C2=A0=C2=A0=C2=A0 anything to an agency - not only is that not a = legal argument or
=C2=A0=C2=A0=C2=A0=C2=A0 concern, it's also not something where they're = obligated to follow
=C2=A0=C2=A0=C2=A0=C2=A0 these comments - it's not a vote or = poll).

=C2=A0That said, political folks have spun things to the public = as
=C2=A0=C2=A0=C2=A0=C2=A0 if it is a =
poll/vote/chance to act. The raise a valid legal
=C2=A0=C2=A0=C2=A0=C2=A0 concern part of the APA of 1946 is omitted. = Moreover the fact that
=C2=A0=C2=A0=C2=A0=C2=A0 third party law firms and others like to submit = comments on behalf
=C2=A0=C2=A0=C2=A0=C2=A0 of clients - there will always be a third party = submitting
=C2=A0=C2=A0=C2=A0=C2=A0 multiple comments for their clients (or = "clients") because that's
=C2=A0=C2=A0=C2=A0=C2=A0 their business.

=C2=A0In the lead up to 2017, the Consumer and Government = Affairs
=C2=A0=C2=A0=C2=A0=C2=A0 Bureau of the FCC =
got an inquiry from a firm asking how they could
=C2=A0=C2=A0=C2=A0=C2=A0 submit 1 million comments a day on an = "upcoming privacy
=C2=A0=C2=A0=C2=A0=C2=A0 proceeding" (their words, astute observers = will note there was no
=C2=A0=C2=A0=C2=A0=C2=A0 privacy proceeding before the FCC in 2017). = When the Bureau asked
=C2=A0=C2=A0=C2=A0=C2=A0 me, I told them either mail us a CD to upload = it or submit one
=C2=A0=C2=A0=C2=A0=C2=A0 comment with 1 million signatures. To attempt = to flood us with 1
=C2=A0=C2=A0=C2=A0=C2=A0 million comments a day (aside from the fact who = can "predict"
=C2=A0=C2=A0=C2=A0=C2=A0 having that many daily) would deny resources to = others. In the
=C2=A0=C2=A0=C2=A0=C2=A0 mess that followed, what was released to the = public was so
=C2=A0=C2=A0=C2=A0=C2=A0 redacted you couldn't see the legitimate = concerns and better paths
=C2=A0=C2=A0=C2=A0=C2=A0 that were offered to this = entity.

=C2=A0And the FCC isn't alone. EPA, FTC, and other = regulatory
=C2=A0=C2=A0=C2=A0=C2=A0 agencies have had =
these hijinks for years - and before the
=C2=A0=C2=A0=C2=A0=C2=A0 Internet it was faxes, mass mimeographs = (remember blue ink?), and
=C2=A0=C2=A0=C2=A0=C2=A0 postcards.The Administrative Conference of the = United States
=C2=A0=C2=A0=C2=A0=C2=A0 (ACUS) - is the body that is supposed to = provide consistent
=C2=A0=C2=A0=C2=A0=C2=A0 guidance for things like this across the = U.S. government. I've
=C2=A0=C2=A0=C2=A0=C2=A0 briefed them and tried to raise awareness of = these issues - as I
=C2=A0=C2=A0=C2=A0=C2=A0 think fundamentally this is a **process** = question that once
=C2=A0=C2=A0=C2=A0=C2=A0 answered, tech can support. However they're not = technologies and
=C2=A0=C2=A0=C2=A0=C2=A0 updating the interpretation of the process = isn't something lawyers
=C2=A0=C2=A0=C2=A0=C2=A0 are apt to do until the evidence that things = are in trouble is
=C2=A0=C2=A0=C2=A0=C2=A0 overwhelming.

=C2=A052 folks wrote a letter to them - and to GSA - back in = 2020.
=C2=A0=C2=A0=C2=A0=C2=A0 GSA had a rulemaking =
of its own on how to improve things, yet
=C2=A0=C2=A0=C2=A0=C2=A0 oddly never published any of the comments it = received (including
=C2=A0=C2=A0=C2=A0=C2=A0 ours) and closed the rulemaking quietly. Here's = the letter:
=C2=A0=C2=A0=C2=A0=C2=A0 https://tinyurl.com/= letter-signed-52-people

=C2=A0And here's an article published in OODAloop about this - = and
=C2=A0=C2=A0=C2=A0=C2=A0 why Generative AI is =
probably going to make things even more
=C2=A0=C2=A0=C2=A0=C2=A0 challenging:
=C2=A0=C2=A0=C2=A0=C2=A0 https://www.oodaloop.= com/archive/2023/04/18/why-a-pause-on-ai-development-is-not-the-answer-an= -insiders-perspective/

=C2=A0[snippet of the article] Now in 2023 and Beyond: = Proactive
=C2=A0=C2=A0=C2=A0=C2=A0 Approaches to AI and =
Society

=C2=A0Looking to the future, to effectively address the = challenges
=C2=A0=C2=A0=C2=A0=C2=A0 arising from AI, we =
must foster a proactive, results-oriented, and
=C2=A0=C2=A0=C2=A0=C2=A0 cooperative approach with the public. Think = tanks and universities
=C2=A0=C2=A0=C2=A0=C2=A0 can engage the public in conversations about = how to work, live,
=C2=A0=C2=A0=C2=A0=C2=A0 govern, and co-exist with modern technologies = that impact society.
=C2=A0=C2=A0=C2=A0=C2=A0 By involving diverse voices in the = decision-making process, we can
=C2=A0=C2=A0=C2=A0=C2=A0 better address and resolve the complex = challenges AI presents on
=C2=A0=C2=A0=C2=A0=C2=A0 local and national = levels.

=C2=A0In addition, we must encourage industry and political = leaders
=C2=A0=C2=A0=C2=A0=C2=A0 to participate in =
finding non-partisan, multi-sector solutions if
=C2=A0=C2=A0=C2=A0=C2=A0 civil societies are to remain stable. By = working together, we can
=C2=A0=C2=A0=C2=A0=C2=A0 bridge the gap between technological = advancements and their
=C2=A0=C2=A0=C2=A0=C2=A0 societal = implications.

=C2=A0Finally, launching AI pilots across various sectors, such = as
=C2=A0=C2=A0=C2=A0=C2=A0 work, education, =
health, law, and civil society, is essential. We
=C2=A0=C2=A0=C2=A0=C2=A0 must learn by doing on how we can create = responsible civil
=C2=A0=C2=A0=C2=A0=C2=A0 environments where AIs can be developed and = deployed responsibly.
=C2=A0=C2=A0=C2=A0=C2=A0 These initiatives can help us better understand = and integrate AI
=C2=A0=C2=A0=C2=A0=C2=A0 into our lives, ensuring its potential is = harnessed for the
=C2=A0=C2=A0=C2=A0=C2=A0 greater good while mitigating = risks.

=C2=A0In 2019 and 2020, a group of fifty-two people asked = the
=C2=A0=C2=A0=C2=A0=C2=A0 Administrative =
Conference of the United =
States (which helps guide
=C2=A0=C2=A0=C2=A0=C2=A0 rulemaking procedures for federal agencies), = General Accounting
=C2=A0=C2=A0=C2=A0=C2=A0 Office, and the General Services Administration = to call attention
=C2=A0=C2=A0=C2=A0=C2=A0 to the need to address the challenges of = chatbots flooding public
=C2=A0=C2=A0=C2=A0=C2=A0 commenting procedures and potentially crowding = out or denying
=C2=A0=C2=A0=C2=A0=C2=A0 services to actual humans wanting to leave a = comment. We asked:

=C2=A01. Does identity matter regarding who files a comment or = not
=C2=A0=C2=A0=C2=A0=C2=A0 =E2=80=94 and must =
one be a U.S. =
person in order to file?

=C2=A02. Should agencies publish real-time counts of the number = of
=C2=A0=C2=A0=C2=A0=C2=A0 comments received =
=E2=80=94 or is it better to wait until the end of a
=C2=A0=C2=A0=C2=A0=C2=A0 commenting round to make all comments = available, including counts?

=C2=A03. Should third-party groups be able to file on behalf = of
=C2=A0=C2=A0=C2=A0=C2=A0 someone else or not =
=E2=80=94 and do agencies have the right to remove
=C2=A0=C2=A0=C2=A0=C2=A0 spam-like = comments?

=C2=A04. Should the public commenting process permit = multiple
=C2=A0=C2=A0=C2=A0=C2=A0 comments per =
individual for a proceeding =E2=80=94 and if so, how many
=C2=A0=C2=A0=C2=A0=C2=A0 comments from a single individual are too many? = 100? 1000? More?

=C2=A05. Finally, should the U.S. government itself = consider, given
=C2=A0=C2=A0=C2=A0=C2=A0 public perceptions =
about potential conflicts of interest for any
=C2=A0=C2=A0=C2=A0=C2=A0 agency performing a public commenting process, = whether it would be
=C2=A0=C2=A0=C2=A0=C2=A0 better to have third-party groups take = responsibility for
=C2=A0=C2=A0=C2=A0=C2=A0 assembling comments and then filing those = comments via a validated
=C2=A0=C2=A0=C2=A0=C2=A0 process with the = government?

=C2=A0These same questions need pragmatic pilots that involve = the
=C2=A0=C2=A0=C2=A0=C2=A0 public to co-explore =
and co-develop how we operate effectively
=C2=A0=C2=A0=C2=A0=C2=A0 amid these technological shifts. As the = capabilities of LLMs
=C2=A0=C2=A0=C2=A0=C2=A0 continue to grow, we need positive change = agents willing to tackle
=C2=A0=C2=A0=C2=A0=C2=A0 the messy issues at the intersection of = technology and society.
=C2=A0=C2=A0=C2=A0=C2=A0 The challenges are immense, but so too are the = opportunities for
=C2=A0=C2=A0=C2=A0=C2=A0 positive change. Let=E2=80=99s seize this = moment to create a better
=C2=A0=C2=A0=C2=A0=C2=A0 tomorrow for all. Working together, we can = co-create a future that
=C2=A0=C2=A0=C2=A0=C2=A0 embraces AI=E2=80=99s potential while = mitigating its risks, informed by
=C2=A0=C2=A0=C2=A0=C2=A0 the hard lessons we have already = learned.

=C2=A0Full article:
=C2=A0=C2=A0=C2=A0=C2=A0 https://www.oodaloop.=
com/archive/2023/04/18/why-a-pause-on-ai-development-is-not-the-answer-an=
-insiders-perspective/

=C2=A0Hope this helps.


=C2=A0On Thu, Oct 5, 2023 at 4:44
=E2=80=AFPM Jack Haverty via = Nnagain
=C2=A0=C2=A0=C2=A0=C2=A0 =
<nnagain@lists.bufferbloat.net> =
wrote:
 
=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 

=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 =
Thanks for all your efforts to keep the "feedback loop" =
to
=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 =
=C2=A0=C2=A0=C2=A0=C2=A0 the rulemakers =
functioning!
 
=C2=A0=C2=A0 =C2=A0=C2=A0=C2=A0=C2=A0

=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 =
I'd like to offer a suggestion for a hopefully =
politically
=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 =
=C2=A0=C2=A0=C2=A0=C2=A0 acceptable way to =
handle the deluge, derived from my own battles
=C2=A0=C2=A0=C2=A0=C2=A0 with "email" over the years = (decades).
 
=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 

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

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

=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 =
So, my suggestion for handling the deluge of "comments" =
is:
=C2=A0 =
=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0

=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 

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

=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 2/ =
Also make registration optional - anyone can still =
submit
=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 =
=C2=A0=C2=A0=C2=A0=C2=A0 comments anonymously =
if they choose.
 
=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 

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

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

=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 =
This may not reduce the deluge of comments, but I'd =
expect
=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 =
=C2=A0=C2=A0=C2=A0=C2=A0 it to help the =
lawyers and politicians keep their heads above the
=C2=A0=C2=A0=C2=A0=C2=A0 water.
 
=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 

=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 =
Anonymity is an important issue for Net Neutrality too, =
but
=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0=C2=A0 =
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