Wednesday, July 16, 2014

Netflix Submits FCC Comments on Proposed Net Neutrality Rules

We submitted our comments to the Federal Communications Commission in the Net Neutrality proceeding (which the FCC calls “In the matter of protecting and promoting an open Internet.”) We believe the way the FCC handles this issue will have a huge impact on the Internet innovation that has increased consumer choice in so many ways.   

Here are a few highlights from our filing:

  • Netflix believes that achieving strong net neutrality is critical to maintaining a vibrant, open Internet to promote free expression, diversity of content, and continued innovation. ISPs should not impede, favor, or charge Internet services that consumers choose to use.  To prevent this, the Commission should adopt clear enforceable anti-discrimination and no-blocking rules for the last mile.  The Commission also must require ISPs to provide sufficient interconnection to cover the capacity demanded and paid for by their customers, without charging access tolls to online content providers. (Comments Page 25)

  • The Commission’s proposal does little to protect the open Internet.  In fact, by endorsing the concept of paid prioritization, as well as ambiguous enforcement standards and processes, the Commission’s proposed rules arguably turn the objective of Internet openness on its head—allowing the Internet to look more like a closed platform, such as a cable television service, rather than an open and innovative platform driven by the virtuous circle. (Comments Page 4)

  • Allowing ISPs to monetize congestion will likely create more congestion, threatening the current model that has made the Internet so successful, and likely raising barriers for innovative services.  (Comments Page 6)

  • Title II provides a solid basis to adopt prohibitions on blocking and unreasonable discrimination by ISPs. …The D.C. Circuit in Verizon pointed to the Commission’s failure to reclassify broadband Internet access as a telecommunications service under Title II as the chief impediment to a solid jurisdictional basis for meaningful open Internet rules. (Comments Page 21)

Anne Marie

Anne Marie Squeo is a member of the Netflix communications team.