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Thanks for all your efforts to keep the "feedback loop" to the
rulemakers functioning! <br>
<br>
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).<br>
<br>
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.<br>
<br>
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.<br>
<br>
So, my suggestion for handling the deluge of "comments" is:<br>
<br>
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.<br>
<br>
2/ Also make registration optional - anyone can still submit
comments anonymously if they choose.<br>
<br>
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.<br>
<br>
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.<br>
<br>
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.<br>
<br>
Anonymity is an important issue for Net Neutrality too, but I'll
opine about that separately.....<br>
<br>
Jack Haverty<br>
<br>
<br>
<div class="moz-cite-prefix">On 10/2/23 12:38, David Bray, PhD via
Nnagain wrote:<br>
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<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>
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<span
style="font-size:10pt;font-family:"Courier New";color:black">Principal,
<a href="https://www.leaddoadapt.com/"
target="_blank" moz-do-not-send="true"><span>LeadDoAdapt</span>
<span>Ventures</span>, Inc.</a> &
Distinguished Fellow <br>
</span></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"
moz-do-not-send="true">Henry S. Stimson
Center</a>, <a
href="https://bens.org/people/dr-david-bray/" target="_blank"
moz-do-not-send="true">Business
Executives for National Security</a><br>
</span></p>
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<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"
moz-do-not-send="true" class="moz-txt-link-freetext">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" moz-do-not-send="true"
class="moz-txt-link-freetext">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" moz-do-not-send="true"
class="moz-txt-link-freetext">https://netdevconf.info/0x17/news/the-maestro-and-the-music-bof.html</a><br>
Dave Täht CSO, LibreQos<br>
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class="moz-txt-link-freetext">https://lists.bufferbloat.net/listinfo/nnagain</a><br>
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