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Wow, that's some seriously high powered stuff they've got there in that letter. I think that, if anything, the level of exposure they've given into the underpinnings of both sandvine as well as the mentality of the whole thing is telling.
They contradict themselves many times in this, saying that they strive to provide
I found this particularly unnerving:
We considered whether some form of metered usage could adequately address the problem. Metered usage would allow us to ensure that we are appropriately distributing the costs of the network usage to those who use the network most. However, metered usage has not been widely accepted in the marketplace, and, in any event, doesnt directly address the issue of congestion in the network. I also find that this is a complete misunderstanding of what the reset packets, and moreover the whole reset-packet based shaping architecture is like: This action is nothing more than the system saying that it cannot, at that moment, process additional high-resource demands without becoming overwhelmed, just as a traffic light regulates the entry of additional vehicles onto a freeway during rush hour. One would not claim that the car is blocked or prevented from entering; rather, it is briefly delayed, then permitted onto the freeway in its turn while all other traffic is kept moving as expeditiously as possible. Not only is the use of an analogy such as this overly simplified, it's fundamentally wrong. Sending a reset packet is more along the lines of allowing the traffic to proceed through the intersection at a green light, yet suddenly alerting the driver that they've ran a red light and need to reverse back across the intersection. It's flawed because the connections are actively being rejected.
Comcasts network management practices are not discriminatory and are entirely agnostic as to the content being transmitted, where it is being sent from or to, or the identity of the sender or receiver. This is just an outright lie, considering that they themselves admit to targeting specific protocols (BT/P2P) and the upstream path in particular for sandvine throttling. What they've said here is that they employ a completely protocol-agnostic QoS policy (essentially the pure definition of Net Neutrality), yet in the course of the document, shoot it all to pieces. This is a complete fabrication I hope the FCC doesn't let be pulled over itself.
Comcast does not block peer-to-peer (P2P) protocols. This is entirely semantics. It's clear that all that Comcast has to defend itself is its unending stream of semantic, lawyer-esque semantics about what constitutes "blocking." -- "Some people never see the light till it shines thru bullet holes." -Bruce Cockburn
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  funchords Robb Premium,MVM join:2001-03-11 Hillsboro, OR
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edit: July 24th, @02:34AM
| said by Nerdtalker :I found this particularly unnerving: We considered whether some form of metered usage could adequately address the problem. Metered usage would allow us to ensure that we are appropriately distributing the costs of the network usage to those who use the network most. However, metered usage has not been widely accepted in the marketplace, and, in any event, doesnt directly address the issue of congestion in the network. It's funny you should pick that. They've also admitted in a previous filing HERE, that Sandvine doesn't directly address the issue of congestion in the network, either. Specifically, Comcasts current P2P management is triggered when the number of P2P uploads in a given area for a particular P2P protocol reaches a certain, pre-determined level, regardless of the level of overall network traffic at that time, and regardless of the time of day when the applicable P2P protocol threshold is reached. That's right!! -- Sandvine doesn't use congestion as a factor. It simply counts connections that it thinks are uploading and cuts off anything above that count, even if there is bandwidth available! It's what I had been saying all along that the level of interference didn't go up and down following probable congestion patterns (despite my obvious lack of qualifications ), but was the same level 24/7.
So, here's their defense? Given the choice of preventing congestion by ...
A. publicly organizing their business model with "metered usage" which was not widely accepted in the marketplace nor directly addressing congestion, or B. secretly blocking uploads using packet forgery methods and also not widely accepted in the marketplace and ALSO not directly addressing congestion ... Comcast chose "B"? Not that I would want metered usage, but at least it's honest.
Our reply to that disclosure is HERE and most of the geek stuff starts on page 8. -- Robb Topolski -= funchords.com =- Hillsboro, Oregon Comcast: We never did anything wrong, and we'll never do it again...
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