<div dir="ltr"><div><div><div><div>Greetings all and thank you Dave Taht for that very kind intro... <br><br></div>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". <br><br></div>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. <br><br></div>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.
<br><br></div>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. <br><br>
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. <div dir="auto"><br></div><div dir="auto">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. <div dir="auto"><br></div><div dir="auto">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. </div><div dir="auto"><br></div><div dir="auto">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). </div><div dir="auto"><br></div><div dir="auto">So with Net Neutrality back on the agenda - here’s a simple <span>prediction</span>,
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? <br><br></div><div>Hope this helps and with highest regards, <br><br></div><div>-d. <br><span class="gmail_signature_prefix">-- </span><br><div dir="ltr" class="gmail_signature"><div dir="ltr"><div dir="ltr"><div><div>
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<span style="font-size:10pt;font-family:"Courier New";color:black">Principal,
<a href="https://www.leaddoadapt.com/" target="_blank"><span>LeadDoAdapt</span> <span>Ventures</span>, Inc.</a> & Distinguished Fellow <br></span></div><div>
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<p class="MsoNormal"><span style="font-size:10pt;font-family:"Courier New";color:black"><a href="https://www.stimson.org/ppl/david-bray/" target="_blank">Henry S. Stimson Center</a>, <a href="https://bens.org/people/dr-david-bray/" target="_blank">Business Executives for National Security</a><br></span></p><p class="MsoNormal"><span style="font-size:10pt;font-family:"Courier New";color:black"><br></span></p>
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</div><br><div class="gmail_quote"><div dir="ltr" class="gmail_attr">On Mon, Oct 2, 2023 at 2:15 PM Dave Taht via Nnagain <<a href="mailto:nnagain@lists.bufferbloat.net">nnagain@lists.bufferbloat.net</a>> wrote:<br></div><blockquote class="gmail_quote" style="margin:0px 0px 0px 0.8ex;border-left:1px solid rgb(204,204,204);padding-left:1ex">All:<br>
<br>
I have spent the last several days reaching out to as many people I<br>
know with a deep understanding of the policy and technical issues<br>
surrounding the internet, to participate on this list. I encourage you<br>
all to reach out on your own, especially to those that you can<br>
constructively and civilly disagree with, and hopefully work with, to<br>
establish technical steps forward. Quite a few have joined silently!<br>
So far, 168 people have joined!<br>
<br>
Please welcome Dr David Bray[1], a self-described "human flack jacket"<br>
who, in the last NN debate, stood up for the non -partisan FCC IT team<br>
that successfully kept the system up 99.4% of the time despite the<br>
comment floods and network abuses from all sides. He has shared with<br>
me privately many sad (and some hilarious!) stories of that era, and I<br>
do kind of hope now, that some of that history surfaces, and we can<br>
learn from it.<br>
<br>
Thank you very much, David, for putting down your painful memories[2],<br>
and agreeing to join here. There is a lot to tackle here, going<br>
forward.<br>
<br>
[1] <a href="https://www.stimson.org/ppl/david-bray/" rel="noreferrer" target="_blank">https://www.stimson.org/ppl/david-bray/</a><br>
[2] "Pain shared is reduced. Joy shared, increased." - Spider Robinson<br>
<br>
<br>
-- <br>
Oct 30: <a href="https://netdevconf.info/0x17/news/the-maestro-and-the-music-bof.html" rel="noreferrer" target="_blank">https://netdevconf.info/0x17/news/the-maestro-and-the-music-bof.html</a><br>
Dave Täht CSO, LibreQos<br>
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</blockquote></div>