[NNagain] Introduction: Dr. David Bray

Jack Haverty jack at 3kitty.org
Mon Oct 9 22:56:08 EDT 2023


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...?]

 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.  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.  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. Economics has notions of Supply 
and Demand and Cost Curves. 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. 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 PM Vint Cerf <vint at google.com> 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 AM David Bray, PhD via Nnagain
>     <nnagain at 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 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
>         — 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 — 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 — 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 — 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 PM Jack Haverty <jack at 3kitty.org>
>         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? 
>             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
>>             <https://davidbray.medium.com/challenges-and-needed-new-solutions-for-open-societies-to-maintain-civil-discourse-part-1-b5ea95f8c679>.
>>             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
>>             <https://tinyurl.com/letter-signed-52-people>(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
>>             <https://davidbray.medium.com/challenges-and-needed-new-solutions-for-open-societies-to-maintain-civil-discourse-part-1-b5ea95f8c679>:
>>
>>
>>             *1. Does identity matter regarding who files a comment or
>>             not — 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 — 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 — 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 — 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
>>             <https://davidbray.medium.com/challenges-and-needed-new-solutions-for-open-societies-to-maintain-civil-discourse-part-2-2f637c472112>.
>>             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’s seize this moment to create a
>>             better tomorrow for all. Working together, we can
>>             co-create a future that embraces AI’s potential while
>>             mitigating its risks
>>             <https://medium.com/peoplecentered/the-need-for-people-centered-sources-of-hope-for-our-digital-future-ahead-ef491dd2703d>,
>>             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 PM Jack Haverty via Nnagain
>>             <nnagain at 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 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.
>>
>>                 Over the years, that principle has been forgotten,
>>                 and the 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.
>>
>>                 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 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
>>                 "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,
>>                 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.   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 actors
>>>                 attempted to flood the system with
>>>                 less-than-authentic comments.
>>>
>>>                 In some respects this is not new. The whole "notice
>>>                 and comment" process is a legacy process that goes
>>>                 back decades. And the FCC (and others) have had
>>>                 postcard floods of comments, mimeographed letters of
>>>                 comments, faxed floods of comments, and now this -
>>>                 which, when combined with generative AI, will be yet
>>>                 another flood.
>>>
>>>                 Which gets me to my biggest concern as a
>>>                 non-partisan in 2023-2024, namely how LLMs might
>>>                 misuse and abuse the commenting process further.
>>>
>>>                 Both in 2014 and 2017, I asked FCC General Counsel
>>>                 if I could use CAPTChA to try to reduce the volume
>>>                 of web scrapers or bots both filing and pulling info
>>>                 from the Electronic Comment Filing System.
>>>
>>>                 Both times I was told *no* out of concerns that they
>>>                 might prevent someone from filing. I asked if I
>>>                 could block obvious spam, defined as someone filing
>>>                 a comment >100 times a minute, and was similarly
>>>                 told no because one of those possible comments might
>>>                 be genuine and/or it could be an ex party filing en
>>>                 masse for others.
>>>
>>>                 For 2017 we had to spin up 30x the number of AWS
>>>                 cloud instances to handle the load - and this was a
>>>                 flood of comments at 4am, 5am, and 6am ET at night
>>>                 which normally shouldn’t see such volumes. When I
>>>                 said there was a combination of actual humans
>>>                 wanting to leave comments and others who were
>>>                 effectively denying service to others (especially
>>>                 because if anyone wanted to do a batch upload of
>>>                 100,000 comments or more they could submit a CSV
>>>                 file or a comment with 100,000 signatories) - both
>>>                 parties said no, that couldn’t be happening.
>>>
>>>                 Until 2021 when the NY Attorney General proved that
>>>                 was exactly what was happening with 18m of the 23m
>>>                 apparently from non-authentic origin with ~9m from
>>>                 one side of the political aisle (and six companies)
>>>                 and ~9m from the other side of the political aisle
>>>                 (and one or more teenagers).
>>>
>>>                 So with Net Neutrality back on the agenda - here’s a
>>>                 simple prediction, even if the volume of comments is
>>>                 somehow controlled, 10,000+ pages of comments
>>>                 produced by ChatGPT or a different LLM is both
>>>                 possible and probably will be done. The question is
>>>                 if someone includes a legitimate legal argument on
>>>                 page 6,517 - will FCC’s lawyers spot it and respond
>>>                 to it as part of the NPRM?
>>>
>>>                 Hope this helps and with highest regards,
>>>
>>>                 -d.
>>>                 -- 
>>>
>>>                 Principal, LeadDoAdapt Ventures, Inc.
>>>                 <https://www.leaddoadapt.com/> & Distinguished Fellow
>>>
>>>                 Henry S. Stimson Center
>>>                 <https://www.stimson.org/ppl/david-bray/>, Business
>>>                 Executives for National Security
>>>                 <https://bens.org/people/dr-david-bray/>
>>>
>>>
>>>
>>>                 On Mon, Oct 2, 2023 at 2:15 PM Dave Taht via Nnagain
>>>                 <nnagain at lists.bufferbloat.net> wrote:
>>>
>>>                     All:
>>>
>>>                     I have spent the last several days reaching out
>>>                     to as many people I
>>>                     know with a deep understanding of the policy and
>>>                     technical issues
>>>                     surrounding the internet, to participate on this
>>>                     list. I encourage you
>>>                     all to reach out on your own, especially to
>>>                     those that you can
>>>                     constructively and civilly disagree with, and
>>>                     hopefully work with, to
>>>                     establish technical steps forward. Quite a few
>>>                     have joined silently!
>>>                     So far, 168 people have joined!
>>>
>>>                     Please welcome Dr David Bray[1], a
>>>                     self-described "human flack jacket"
>>>                     who, in the last NN debate, stood up for the non
>>>                     -partisan FCC IT team
>>>                     that successfully kept the system up 99.4% of
>>>                     the time despite the
>>>                     comment floods and network abuses from all
>>>                     sides. He has shared with
>>>                     me privately many sad (and some hilarious!)
>>>                     stories of that era, and I
>>>                     do kind of hope now, that some of that history
>>>                     surfaces, and we can
>>>                     learn from it.
>>>
>>>                     Thank you very much, David, for putting down
>>>                     your painful memories[2],
>>>                     and agreeing to join here. There is a lot to
>>>                     tackle here, going
>>>                     forward.
>>>
>>>                     [1] https://www.stimson.org/ppl/david-bray/
>>>                     [2] "Pain shared is reduced. Joy shared,
>>>                     increased." - Spider Robinson
>>>
>>>
>>>                     -- 
>>>                     Oct 30:
>>>                     https://netdevconf.info/0x17/news/the-maestro-and-the-music-bof.html
>>>                     Dave Täht CSO, LibreQos
>>>                     _______________________________________________
>>>                     Nnagain mailing list
>>>                     Nnagain at lists.bufferbloat.net
>>>                     https://lists.bufferbloat.net/listinfo/nnagain
>>>
>>>
>>>                 _______________________________________________
>>>                 Nnagain mailing list
>>>                 Nnagain at lists.bufferbloat.net
>>>                 https://lists.bufferbloat.net/listinfo/nnagain
>>
>>                 _______________________________________________
>>                 Nnagain mailing list
>>                 Nnagain at lists.bufferbloat.net
>>                 https://lists.bufferbloat.net/listinfo/nnagain
>>
>
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>
>     -- 
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>     Google, LLC
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>     until further notice
>
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