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ccianet.org • @CCIAnet

31 Jan 2024

On January 29, 2024, the undersigned and CCIA Vice President—Federal Affairs Brian McMillan met with Marco Peraza, Legal Advisor to Commissioner Simington for Wireline issues, to discuss the matters raised in the Notice of Proposed Rulemaking (“NPRM”).2 More specifically, CCIA reiterated its support for the Commission’s proposal to readopt the Open Internet protections against throttling, blocking. [...] The connection-oriented nature of end-to-end SPNP, with its focus on charging based on the actual volumes or value of the traffic, would represent a dramatic change from the existing charging framework operating on the internet.”5 The ITU declined to adopt SPNP. [...] Though a few commenters have addressed the issue to some degree,9 the question of forcing non-telecommunications service providers to remit funds to cover telcos’ network investment is not meaningfully open for public comment10 here.11 The issue raises complex questions, including the anticompetitive potential of Network Usage Fees domestically, the effect of such fees on the ongoing operation of. [...] The Commission should consider ETNO’s request only in the context of the further support it lends for the intended reinstatement of the 2015 Open Internet protections. [...] ETNO’s Comments seem to presage their intent to use points of interconnection as the fulcrum for extracting payment.12 In its Comments (p.2), CCIA supported the Commission’s proposal to include traffic exchange in the definition of BIAS: “Any Internet-bound and Internet-based transmissions occurring along the ‘call path’ of BIAS, including BIAS Internet traffic exchanges, should be included in the.

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