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Cable giant defends Data Discrimination policy with 80 pages of chaff

The Internet was set alight last October, when news broke out that Comcast actively interfered with P2P traffic. Nasty words flew back and forth. Lawsuits were filed. Even the FCC joined the party, kicking off its own investigation early last January.

Fast forward to last Tuesday, when Comcast answered the FCC’s inquiries with an 80 page reply (PDF) that explained the company’s rationale behind its definition of “reasonable network management:”

Notwithstanding the enormous capacity and flexibility of the cable infrastructure, there are (and always will be) some throughput limitations. Thus, the question is not whether all customers will be able to use shared bandwidth indiscriminately… but, rather, how to optimize every customer’s online experience and ability to … use all Internet applications and services.”

Fair enough. Other parts of the document point out that Comcast is more concerned with making sure that their average users can surf the web proper, as opposed to placating the desires of a “vocal minority of users who make the most noise.”

Right there, however, Comcast’s logic falls apart. A quarter of the way through the document – Page 14, according to Acrobat – Comcast defers to the testimony of Congresswoman Mary Bono Mack, who says that “P2P applications are designed to consume as much bandwidth as is available, thus more capacity only results in more consumption.”

So that much is true – but just as true are the numerous other protocols and applications that are also bandwidth intensive. Almost every other non-streaming application works because of similar goals: using as much bandwidth as necessary to obtain optimal results. In some cases, bandwidth requirements are minimal, like in online chat applications. In other cases, however, saturating a user’s limited pipe simply isn’t fast enough, as you simply cannot escape the fact that downloading a file or streaming a high quality video requires a comparatively large amount of data. There are many, many bandwidth hogs out there that are just as good, if not better, at “clogging the tubes” than BitTorrent and its ilk.

Look at Windows Update: every time Microsoft drops a big patch on the Windows masses, literally hundreds of millions of computers throughout the world will compete for space to download it – and it is quite often very large: a 2005 estimate from Chris St. Amand of the Microsoft Operations team pegged Windows update traffic at 10-15 gigabits per second from the main download center during peak periods.

Comcast users represent a significant chunk of that number, being that the ISP is currently the #2 provider of Internet services in the United States. Where’s Comcast stepping in to manage its subscribers’ use of Windows Update?

The point I’m trying to make here is that BitTorrent isn’t the only bandwidth demon that haunts ISPs, and for Comcast and Congresswoman Bono Mack to accuse it of consuming “as much bandwidth as possible,” without mentioning many of the other applications that do as well, is obfuscating the real issue: that Internet consumption is expanding faster than ISPs would like it to.

Services like BitTorrent, and other P2P apps, have a legitimate place in today’s and tomorrow’s Internet. A number of progressive companies – Blizzard Entertainment, Joost, and others – use BitTorrent, or BitTorrent-like systems, to offload content away from the old guard of expensive, centralized client-server models and towards newer, P2P models. While this model does introduce an extra burden on the ISPs, I would think that ISPs should be responding to the needs of their customers, and not the other way around.

Food for thought: if Comcast invested all the money spent on excessive “network management” towards expanding the weak points of its infrastructure, how much further would the company be? How much further would the quality of our Internet service be? Instead of cracking down on protocols that Comcast deems unworthy, wouldn’t it be easier to promise – and enforce – a usable minimum of bandwidth to subscribers, and allow the rest of the pipe to be a free-for-all?

You can tell that Comcast is on the defensive. In the places where its response to the FCC isn’t littered with narcissistic praise, it constantly qualifies its “network management” practices with words like “little” or “minor” or “reasonable,” and there’s always an emphasis on the well-being of “all” users. Frequently these qualifiers appear italicized for emphasis. Don’t get me wrong, I’m all for reasonable network management – and indeed Comcast names many examples of reasonable network management in other companies – but none of those definitions include Comcast’s, who thinks that injecting forged disconnect packets into P2P sessions is “reasonable.”

Comcast contends that its practices are necessary so that it can stay viable in an intensely competitive – hah! – industry. I am officially calling shenanigans on this claim. I think Comcast is unwilling to further invest in its infrastructure’s weak points despite its considerable financial growth in 2007, and that it is unwilling to support an Internet that is growing faster than its master plan.

The Greek philosopher Heraclitus once wrote that “nothing endures but change.” Comcast, just like most any big company, is simply fighting change – and all the disruptions that come with it.

But we all know what happens when you fight change, right?

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RE: Sorry Tom, but..
By KristopherKubicki on 2/19/2008 12:36:02 PM , Rating: 3
I've heard figures all over the board as far as P2P data. I've also heard that YouTube is 15% of the Internet traffic; that spam is 80% of all email; that MySpace serves more pageviews than Google and Yahoo combined.

(Tom works at an ISP BTW, at least for the next two days before he becomes at DT employee full time)

I've not seen concrete, accurate studies of traffic on the Internet. I don't suspect they exist. Even though we're a couple decades into it, the Internet is still in a state of flux anyway. What could be said to be true just three years ago is totally bogus today.

I think we need to ride it out a bit before proclaiming hard numbers in any direction.

RE: Sorry Tom, but..
By geddarkstorm on 2/19/2008 12:42:10 PM , Rating: 1
And don't forget on-line games! Those can be quite bandwidth intensive. What percentages do they accumulate to? Heck, what percentage of traffic is WoW alone?

RE: Sorry Tom, but..
By masher2 on 2/19/2008 12:49:50 PM , Rating: 2
Wow has only 8 million subscribers, the average who plays what, about 20 hours a week max? And the game itself consumes less than 128kb bandwidth.

Compared to the much larger P2P user base, consuming 100% of their 3mb, 6mb, or even 30mb pipe, often on a 24x7 basis, I'm sure you can see the two aren't comparable at all.

RE: Sorry Tom, but..
By geddarkstorm on 2/19/2008 1:00:12 PM , Rating: 2
I've used P2P for legitimate reasons (OC remix collections), and I've never achieved speeds, download or upload combined, that were even 2/3rds of 128kb/s on a 3mb/s connection. P2P seems extremely slow in my experience, although that could easily not be the norm, but I'd like to see actual figured on the matter before I'm swayed that P2P accounts for most traffic.

RE: Sorry Tom, but..
By masher2 on 2/19/2008 1:30:38 PM , Rating: 2
As my other post indicates, the estimate comes from a hardware vendor of traffic monitoring equipment; it's not a figure pulled out of a hat.

RE: Sorry Tom, but..
By Christopher1 on 2/19/2008 2:40:54 PM , Rating: 3
As my other post indicates, the estimate comes from a hardware vendor of traffic monitoring equipment; it's not a figure pulled out of a hat.

And you don't see the problem with that, in that you are taking the word of a company that has a FINANCIAL STAKE in selling equipment to 'monitor' excessive traffic as rote truth?
Stupid, to the extreme.

RE: Sorry Tom, but..
By masher2 on 2/19/2008 3:01:33 PM , Rating: 2
You make an excellent example of the human ability to rationalize away inconvenient data that doesn't fit your preconceptions.

IPogue has no "financial stake" in publicizing false statistics on total P2P traffic. In fact, just the opposite. Their livelihood depends on their ability to generate accurate figures on traffic breakdowns. False data would seriously jeopardize their product image.

They have absolutely nothing to gain from inflating one particular traffic source over another. Such a claim is-- as you yourself put it -- "stupid to the extreme".

RE: Sorry Tom, but..
By The0ne on 2/20/2008 1:07:36 PM , Rating: 2
He just doesn't want to believe anything that he didn't say for himself from ANYONE or ANY BODY. This should mean he shouldn't be voting, shouldn't be buying name brand items, eating at fine restuarants, etc. That's because we all know people do research and from that make their choices. But maybe that's too far out for him :)

RE: Sorry Tom, but..
By SandmanWN on 2/19/2008 3:10:36 PM , Rating: 2
Their company makes hardware that breaks down ALL traffic and creates an analysis of that information. They have no stake in what traffic gets revealed in the process. Their stake is only that the data is accurate.

Its the ISP that has a stake in the data itself, not the hardware monitor provider and their equipment.

RE: Sorry Tom, but..
By FITCamaro on 2/20/2008 1:45:29 PM , Rating: 2
MMOs are designed to use the least amount of bandwidth possible so that anyone can play. They come nowhere close to comparing to P2P or Bittorrent. I'd say you're probably using less than 100MB of bandwidth in an hour of play vs. about 1.8GB of bandwidth in an hour with a maxed out 4Mbps connection.

RE: Sorry Tom, but..
By masher2 on 2/19/2008 12:43:51 PM , Rating: 2
Peer-to-peer applications account for between 50 percent and 90 percent of overall Internet traffic, according to a survey this year by ipoque GmbH, a German vendor of traffic-management equipment.

I can't vouch for the accuracy of their figures, but given their hardware role, they'd certainly be in a position to know.

RE: Sorry Tom, but..
By IGoodwin on 2/19/2008 1:26:40 PM , Rating: 2
It is good that you posted the full quote about the statistic's range...

However, I hope this is not indicative of how you collect figures for your articles. A figure you have quoted with a 40% spread, which makes it obviously highly subjective, and you use the higher bound without qualification in an earlier post!

RE: Sorry Tom, but..
By masher2 on 2/19/2008 1:38:15 PM , Rating: 2
Without qualification? I specifically said "up to 90%" in my post, and further qualified it with "some surveys". I'd call that accurately qualified, especially given I was working from memory of a story read half a year earlier.

Point in fact, the range is primarily geographically based. The 50% low range comes from the Middle East (which accounts for a very low percentage of overall Internet traffic anyway). The high range comes from Europe. In Eastern Europe, it can go even higher still -- as high as 95% at times.

RE: Sorry Tom, but..
By IGoodwin on 2/19/2008 2:29:57 PM , Rating: 3
Lets just say we see your word usage highlighted the 90% figure without adequate qualification.

Anecdotal observation of peoples responses would indicate that the 'up to' part of your sentance was not sufficient to overshadow the 90% figure, leading to a skew in perception.

As I mentioned before, it is good that you do provide full quotes, as, in general, I like reading your material.

"If a man really wants to make a million dollars, the best way would be to start his own religion." -- Scientology founder L. Ron. Hubbard

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