Mark Goldberg


www.mhgoldberg.com





#CTS20

It isn’t neutrality

Comcast and Level 3 get into a tiff over interconnection fees and the blogosphere screams out “net neutrality”. This issue does not mean the end of the internet as we know it, despite the rhetoric of the blogosphere that has been conscripted by Level 3 to their side of the issue.

Level 3 was first to invoke the FCC’s Policy Principles in its statement on Monday. Comcast responded, saying that Level 3’s traffic was out of balance by a 5:1 ratio on its peering interconnection. Level 3 replied today.

Comcast has a clearly stated peering policy [Settlement-Free Interconnection] that would seemingly apply to all parties. Among other requirements, it says:

Applicant must maintain a traffic scale between its network and Comcast that enables a general balance of inbound versus outbound traffic.

Level 3 appears to have failed that balance, by a very large margin. This is not a naive, unsophisticated customer that had the traffic imbalance come out of the blue. This is a straight commercial issue between two very large companies.

It appears to me that any other interconnecting company would be told the same thing, that it no longer qualifies for Settlement Free Interconnection, so here is our other product: Wholesale Dedicated IP Transit.

Comcast has to treat all interconnecting carriers the same. Anything else would be discriminatory.

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