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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.<br>
<br>
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. <br>
<br>
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...?]<br>
<br>
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?<br>
<br>
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?<br>
<br>
So, why haven't organizations yet developed rules and mechanisms for
managing electronic discussions....?<br>
<br>
I'd offer two observations and suggestions.<br>
<br>
-----<br>
<br>
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...<br>
<br>
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.<br>
<br>
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.<br>
<br>
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.<br>
<br>
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.<br>
<br>
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.<br>
<br>
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, ...<br>
<br>
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.<br>
<br>
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).<br>
<br>
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?<br>
<br>
-----<br>
<br>
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.<br>
<br>
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. <br>
<br>
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.]<br>
<br>
"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.<br>
<br>
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.<br>
<br>
Suggestion - educate the decision-makers about Back Pressure, using
highway analogies (metering lights, etc.)<br>
<br>
-----<br>
<br>
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.<br>
<br>
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. <br>
<br>
One possibility -- make the "cost" of submitting a million
electronic comments equal to the cost of submitting a million
postcards...?<br>
<br>
Jack Haverty<br>
<br>
<br>
<div class="moz-cite-prefix">On 10/9/23 16:55, David Bray, PhD
wrote:<br>
</div>
<blockquote type="cite"
cite="mid:CA+aeVP_K6dj0bSOUap8WBGvKx-6nhO6y8QghjxoYMcfWGwajRw@mail.gmail.com">
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<div dir="ltr">
<div>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.) <br>
</div>
<div><br>
</div>
<div>The standard historically has been set by the
Administrative Conference of the United States: <a
href="https://www.acus.gov/about-acus"
moz-do-not-send="true" class="moz-txt-link-freetext">https://www.acus.gov/about-acus</a></div>
<div><br>
</div>
<div>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. <br>
</div>
<div><br>
</div>
<div>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). <br>
</div>
<div><br>
</div>
<div>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 <a
href="https://tinyurl.com/letter-signed-52-people"
moz-do-not-send="true" class="moz-txt-link-freetext">https://tinyurl.com/letter-signed-52-people</a>
- as well as individually - I did my darnest to encourage them
to do a standard. <br>
</div>
<div><br>
</div>
<div>There's also the National Academy of Public Administration
which is probably the latest remaining non-partisan forum for
discussions like this too. <br>
</div>
<div><br>
</div>
</div>
<br>
<div class="gmail_quote">
<div dir="ltr" class="gmail_attr">On Mon, Oct 9, 2023 at 7:46 PM
Vint Cerf <<a href="mailto:vint@google.com"
moz-do-not-send="true" class="moz-txt-link-freetext">vint@google.com</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">
<div dir="ltr">David, this is a good list.
<div>FACA has rules for public participation, for example.</div>
<div><br>
</div>
<div>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?</div>
<div><br>
</div>
<div>v</div>
<div><br>
</div>
</div>
<br>
<div class="gmail_quote">
<div dir="ltr" class="gmail_attr">On Tue, Oct 10, 2023 at
8:22 AM David Bray, PhD via Nnagain <<a
href="mailto:nnagain@lists.bufferbloat.net"
target="_blank" 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">
<div dir="ltr">
<div>I'm all for doing new things to make things better.
<br>
</div>
<div><br>
</div>
<div>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.</div>
<div><br>
</div>
<div>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. <br>
</div>
<div><br>
</div>
<div>
<p style="margin-left:40px"><b>1. Does identity matter
regarding who files a comment or not — and must
one be a U.S. person in order to file?</b></p>
<p style="margin-left:40px"><b>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?</b></p>
<p style="margin-left:40px"><b>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?</b></p>
<p style="margin-left:40px"><b>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?</b></p>
<p style="margin-left:40px"><b>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?</b></p>
</div>
<div> <br>
</div>
</div>
<br>
<div class="gmail_quote">
<div dir="ltr" class="gmail_attr">On Sat, Oct 7, 2023 at
4:10 PM Jack Haverty <<a
href="mailto:jack@3kitty.org" target="_blank"
moz-do-not-send="true" class="moz-txt-link-freetext">jack@3kitty.org</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">
<div> Hi again David et al,<br>
<br>
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.<br>
<br>
I'm thinking here more near-term and incremental
steps. You said "These same questions need
pragmatic pilots that involve the public ..."<br>
<br>
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?<br>
<br>
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 ...?<br>
<br>
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?<br>
<br>
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?<br>
<br>
The Internet, and technology such as TCP, began as
an experimental pilot about 50 years ago. Sometimes
pilots become infrastructures.<br>
<br>
FYI, I'm signing this message. Using OpenPGP. I
could encrypt it also, but my email program can't
find your public key.<br>
<br>
Jack Haverty<br>
<br>
<br>
<div>On 10/5/23 14:21, David Bray, PhD wrote:<br>
</div>
<blockquote type="cite">
<div dir="ltr">
<div>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). <br>
</div>
<div><br>
</div>
<div>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. <br>
</div>
<div><br>
</div>
<div>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.
<br>
</div>
<div><br>
</div>
<div>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. <br>
</div>
<div><br>
</div>
<div>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: <a
href="https://tinyurl.com/letter-signed-52-people" target="_blank"
moz-do-not-send="true"
class="moz-txt-link-freetext">https://tinyurl.com/letter-signed-52-people</a></div>
<div><br>
</div>
<div>And here's an article published in OODAloop
about this - and why Generative AI is probably
going to make things even more challenging: <a
href="https://www.oodaloop.com/archive/2023/04/18/why-a-pause-on-ai-development-is-not-the-answer-an-insiders-perspective/"
target="_blank" moz-do-not-send="true"
class="moz-txt-link-freetext">https://www.oodaloop.com/archive/2023/04/18/why-a-pause-on-ai-development-is-not-the-answer-an-insiders-perspective/</a></div>
<div><br>
</div>
<div>[snippet of the article] <strong>Now in
2023 and Beyond: Proactive Approaches to AI
and Society</strong></div>
<div>
<p>Looking to the future, to effectively
address the challenges arising from AI, <a
href="https://davidbray.medium.com/challenges-and-needed-new-solutions-for-open-societies-to-maintain-civil-discourse-part-1-b5ea95f8c679"
target="_blank" moz-do-not-send="true">we
must foster a proactive, results-oriented,
and cooperative approach with the public</a>.
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.</p>
<p>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. </p>
<p>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. </p>
<p>In 2019 and 2020, a group of <a
href="https://tinyurl.com/letter-signed-52-people" target="_blank"
moz-do-not-send="true">fifty-two people
asked the Administrative Conference of the
United States </a>(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. <a
href="https://davidbray.medium.com/challenges-and-needed-new-solutions-for-open-societies-to-maintain-civil-discourse-part-1-b5ea95f8c679"
target="_blank" moz-do-not-send="true">We
asked</a>: </p>
<p style="margin-left:40px"><b>1. Does
identity matter regarding who files a
comment or not — and must one be a U.S.
person in order to file?</b></p>
<p style="margin-left:40px"><b>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?</b></p>
<p style="margin-left:40px"><b>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?</b></p>
<p style="margin-left:40px"><b>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?</b></p>
<p style="margin-left:40px"><b>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?</b></p>
<p>These same questions need pragmatic pilots
that involve the public to <a
href="https://davidbray.medium.com/challenges-and-needed-new-solutions-for-open-societies-to-maintain-civil-discourse-part-2-2f637c472112"
target="_blank" moz-do-not-send="true">co-explore
and co-develop how we operate effectively
amid these technological shifts</a>. 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, <a
href="https://medium.com/peoplecentered/the-need-for-people-centered-sources-of-hope-for-our-digital-future-ahead-ef491dd2703d"
target="_blank" moz-do-not-send="true">we
can co-create a future that embraces AI’s
potential while mitigating its risks</a>,
informed by the hard lessons we have already
learned. <br>
</p>
<p>Full article: <a
href="https://www.oodaloop.com/archive/2023/04/18/why-a-pause-on-ai-development-is-not-the-answer-an-insiders-perspective/"
target="_blank" moz-do-not-send="true"
class="moz-txt-link-freetext">https://www.oodaloop.com/archive/2023/04/18/why-a-pause-on-ai-development-is-not-the-answer-an-insiders-perspective/</a></p>
<p>Hope this helps.</p>
</div>
</div>
<br>
<div class="gmail_quote">
<div dir="ltr" class="gmail_attr">On Thu, Oct 5,
2023 at 4:44 PM Jack Haverty via Nnagain <<a
href="mailto:nnagain@lists.bufferbloat.net"
target="_blank" 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">
<div> 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>On 10/2/23 12:38, David Bray, PhD via
Nnagain wrote:<br>
</div>
<blockquote type="cite">
<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>
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class="gmail_signature">
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style="font-size:10pt;font-family:"Courier New";color:black"><span></span></span></p>
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style="font-size:10pt;font-family:"Courier New";color:black"><span></span></span></p>
</div>
<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>
<div>
<div>
<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>
<p class="MsoNormal"><span
style="font-size:10pt;font-family:"Courier New";color:black"><br>
</span></p>
</div>
</div>
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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" target="_blank"
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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