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Pew Finds Millions of Issues with Net Neutrality Comments

Majority of 22 million filings used temporary or duplicate email addresses

Reprinted from Broadcasting & Cable

Pew Research says it has analyzed all 21.7 million-plus comments filed in the FCC’s Restoring Internet Freedom docket by the comment period deadline of Aug. 30 — more have since been filed unofficially — and found that “many submissions seemed to include false or misleading personal information.”

It said that a majority (57%) “used duplicate, temporary or disposable email addresses and many individual names appeared thousands of times.” In fact, the most common name for a filer was “Net Neutrality.”

The report appears to confirm what many have been saying about the docket, which has drawn plenty of attention since it was opened, including various reports of form submissions, alleged DDoS attacks, and fake emails generated by fake email generators. Hill Democrats called for investigations of the docket, and FCC chairman Ajit Pai has said the FCC was going to err on the side of inclusiveness, which meant accepting some level of nuisance and mass-generated comments.

Pew said that only 6% represented “unique” comments, while 94% were multiples, in some cases hundreds of thousands of times, with thousands submitted at the exact same time. Pew labeled that “clear evidence of organized campaigns to flood the comments with repeated messages.”

Pew also said its findings were also evidence of how commenters were using technology to make their points.

In the most “prolific” case of instantaneous filings, 475,482 comments were submitted on July 19 at precisely 2:57:15 p.m. EDT, said Pew. There were four instances in which more than 50,00 comments were filed instantaneously, and they included both pro-regulation and pro-deregulation mass filings (two of each).

In fact only seven comments comprised 38% of all the submissions during the four-month comment period, and the same 30 comments represented a majority of the comments filed, or over 10 million.

“The Center’s analysis of these submissions finds that the comments present challenges to anyone hoping to understand the attitudes of the concerned public regarding net neutrality,” the report’s authors concluded.

Pew did not analyze the content of the filings and said it was not passing judgment on the validity of the comments or commenters, however they were filed and in whatever number.

Other findings include:

  • “On nine different occasions more than 75,000 comments were submitted at the very same second, often including identical or highly similar comments”
  • “Thousands of submissions featured duplicate names or even non-names such as, ‘Net Neutrality,’ ‘The Internet,’ ‘17-108,’ among others”
  • “[Only] 3% of comments definitively went through the FCC’s email verification process.”

Pew suggests that the FCC was a bit lax in vetting the veracity of the comments.

“In theory, the process for submitting a comment to the FCC included a validation technique to ensure the email address submitted with each comment came from a legitimate account,” the reports said, based on the submission form’s statement that all information, including names and addresses of commenters, would be made public. “However, the center’s analysis shows that the FCC site does not appear to have utilized this email verification process on a consistent basis. According to this analysis of the data from the FCC, only 3% of the comments definitively went through this validation process,” Pew says, adding: “In the vast majority of cases, it is unclear whether any attempt was made to validate the email address provided.”

“As a result, in many cases commenters were able to use generic or bogus email addresses and still have their comments accepted by the FCC and posted online.”

Just this week, in a list of net neutrality “myths and facts”, the chairman’s office addressed the docket issues this way, providing its own analysis.

“The commenting process is not an opinion poll — and for good reason. For example, one-third of all comments consist of a single, pro-Title II sentence: “I am in favor of strong net neutrality under Title II of the Telecommunications Act.” These 7,568,949 identical comments, however, are associated with only 50,508 unique names and street addresses. Indeed, 7,562,080 of these comments come from 45,001 “individuals” using email addresses from fakemailgenerator.com and submitting the same comment more than 90 times each. In another example, over 400,000 comments supporting Title II purport to come from “individuals” residing at the same address in Russia. In any case, as required by federal law, the chairman’s plan is based on the facts and the law rather than the quantity of comments.”

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