Packet Loves Eyeballs - Which Is Why We've Just Filed Comments To The FCC

October 03rd, 2014

Adam Rothschild

Adam Rothschild

SVP, Network
As we work to redefine the hosting experience, we challenge ourselves in various areas. Among these is reachability: how can we develop a network which is insanely fast and available, not just inside our network, but from the entire global Internet?

As we work to redefine the hosting experience, we challenge ourselves in various areas. Among these is reachability: how can we develop a network which is insanely fast and available, not just inside our network, but from the entire global Internet?

A key part of this equation is reachability into broadband (e.g. cable, fiber, DSL) access providers, lovingly referred to as "eyeball providers". Connectivity into these networks comes in many shapes and sizes.  Many times, we'll work with these networks to exchange traffic through a method called "settlement-free interconnection": we each work to connect our networks at a common point, and we enter into an agreement predicated on mutual benefit; no money exchanges hands. We might also connect to a network using a wide variety of third-party network providers, who we pay to connect us to other networks: for instance when we're delivering traffic to a broadband network far away in a rural region. There are many different configurations and provider options, given a competitive backbone marketplace. When engineered correctly, both peering and transit result in strong connectivity, and happy mutual customers.

Unfortunately, a select few of the largest providers -- namely AT&T, Comcast, Time Warner Cable, and Verizon -- have decided to re-write the rules on how this engagement should work. While broadband networks typically operate networks free of congestion, and maintain reachability through a variety of means, these large networks have decided to erect a walled garden, where a company like ours must obtain direct links and pay access charges, known as "paid peering". If we don't obtain these direct links, there are no third-party providers from which we can buy connectivity, without facing heavy packet loss during peak times of day. We consider this practice anticompetitive, at odds with how Internet engineering typically functions, and ultimately damaging to our industry. Additionally, as Comcast and Time Warner look to merge, we worry their eyeballs will become harder and harder to reach over time.

This is why we filed comments to that effect to the FCC yesterday clarifying and disputing comments made by Comcast and Time Warner to the FCC that claim otherwise. We urge our customers and industry colleagues to read our filing (http://apps.fcc.gov/ecfs/document/view?id=60000870474), and to join in the process (http://apps.fcc.gov/ecfs/) with feedback of their own.

- Adam Rothschild, SVP, Engineering

Edit: since the fcc website appears to have chronic uptime issues, here is a direct link to a pdf of the filing PacketFCCLetter-10022014