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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 MatthiasF on 2/20/2008 10:21:03 AM , Rating: 2
I support P2P bandwidth throttling. The biggest reason, which seems to be left out in the debates, is the fact that BitTorrent and gnutella clients alike both try to make as many connections as allowed to download a file and use as much bandwidth as possible or allowed for each connection.

If you have a massive base that has no limits to the speed governing their constant traffic (assuming most clients are left open constantly to allow others to download) then they will always take up a significant chunk of the available bandwidth.

If today the average broadband line is 1 mbit upload and in a few years that doubles or tripples, so will the overall load being applied to the residential networks by these softwares.

Consider this, the average cost of a residential router for home is around $100. The average cost of a commercial router capible of DS3 speeds is over $10,000. DS3s can handle about 25 households at 2 mbits. At 60 million households, do the math. That's 2.4 Trillion US dollars so that you guys can share rediculious crap like music and videos.

Don't like the numbers? I was being conservative. Tweak them however you like, but you e-hippies are so far out of reality it's not funny. You'll never pay enough to support upgrades that extensive and yet you expect more and more.

The rest of us shouldn't need to pay for your bad habits. The net neutrality act was shot down and the freeloading mentality being spread (even by this blog post) is costing us more and more it seems.


RE: Sorry Tom, but..
By Methusela on 2/20/2008 3:25:44 PM , Rating: 2
Sorry, buddy, but you're wrong.

In general, ISPs oversell their bandwidth by a factor of 4-10. It used to be a factor of 12 or 15, back in the dialup days. This means that for every DS3 circuit, or 45mbit synchronous pipe, you most likely have between 90 and 225 people serviced.

Let's take the middle ground for our figures, or 160 people per 45mbit of bandwidth. At 60 million households, that's actually only $3,750,000,000 in capital expenditures for routing equipment. I think this estimate is still far too high, since this isn't a recurring expense.

In the end, that's just not a whole lot of money spread across so many different ISPs. Consider that it's only $62.50 per household, I'm just not convinced that you know what you're talking about, not to mention your spelling.


RE: Sorry Tom, but..
By MatthiasF on 2/20/2008 5:54:18 PM , Rating: 2
Oversold in the PAST, before the days of P2P. We're talking about what's necessary for the future.

If the mean (or worse the median) average for broadband usage increases substantially like has been hinted by not only all the statistics flying around but Comcast's actions of which you guys are complaining, they probably won't be overselling at all in the no-so-distance future.

Anyway, my calculation was way off. It should be $24 billion, not $2.4 trillion, for my scenario. Not sure where those two zeros came from in Excel (and of course I didn't save the file).

With that in mind, I'm changing my position. Comcast is a bunch of cheap bastards.

Verizon spends $15-18 billion a year upgrading their network, no reason why Comcast can't keep on par for their subscriber base (which is most likely smaller).

Oh, and on the spellcheck smack, I'm using IE6 today. I'm use to Firefox's form spellchecker. Hmmmm... can't wait for version 3.


RE: Sorry Tom, but..
By masher2 (blog) on 2/20/2008 8:41:43 PM , Rating: 1
Err, you're just counting the cost of the routers. That's peanuts. The real money is spent on the cables between those routers, as well as all the labor required to support and maintain the network. And it's not cheap.

For people who think it's is all lightness and air, fun and profits, remember that three of the top 10 largest corporate bankruptcies in history (including Worldcom, the very largest of them all) were all communications companies.

Maintaining a modern, national data network is *expensive*. If its not done just right, it costs much more than customers are willing to pay...and the company quickly loses billions, and folds up shop.


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