To my qualifications: Although obviously not verifiable via this format, I hold a BS and MS in Computer Science, with focus on broad software engineering practices, machine learning, and a computer vision. In industry I have worked directly on public and private APIs (Application Programming Interfaces) as well as the software and networking required to power those APIs "behind the scenes," which has necessitated a passing understanding of the OSI reference model and practical implementation details of modern networking infrastructure of the internet at large and of cloud computing providers (e.g., AWS, GCE, etc.). I consider myself to be "highly technical" compared to the average consumer, but of at most average technical skill compared to my peers in fields relevant to the docket.

Broadly: Multiple references are made in this section to 2 key concepts: The classification of (broadband) internet connection as data services because of the "functions [the service] makes available to its end users" (par11) and four "Internet Freedoms" (par13). The fourth of these freedoms is to "acquire service plan information." One data service (or collection of services) referenced is control and manipulation of data in transit for network health (ie, "throttling"). It is thus important that consumers be able to acquire any relevant information on the throttling and traffic shaping practices of ISPs, so that their services are not black boxes (else consumers will not be able to make informed decisions about ISPs competing in the market).

Broadly: A chief concern of not regulating ISPs is that many modern ISPs are also holders of, or subsidiaries to, media conglomerates. Having control of what information is broadcast and how that information is broadcast is a dangerous situation ripe for abuse by bad actors who could wield undue influence on political or economic beliefs of the average consumer.

Par11:  While the commission's Order may have been reasonable at the time of its issuance, the internet landscape of 2017 is very different from the landscape of 2002. It is certainly possible nowadays to treat one's ISP as a "dump pipe" for data transmission (and indeed, most consumers, being unaware of the technical implementation of network infrastructure, do!) and ignore any data information service offerings (email, storage, etc.) that might be offered by the ISP. Furthermore, allowing companies to shield services that could be regulated under Title 2 by offering services which do not alludes to an obvious loophole where  said companies could make such an offering avoid regulatory oversight regardless of the quality of either service.

Par27: The Commission has conflated Internet Service Providers with services provided over the internet. If, for example, my ISP is Comcast/Xfinity, I am capable of searching for information on a popular celebrity, finding their social media account, reading their updates, and publishing comments of my own. However, my ISP is not responsible nor involved in the actual data transmissions/transactions required to power these activities; Google provides search, Twitter provides status update platform, Facebook allows me to publish social media messages of my own, etc. Comcast in this case can (and should) only see, handle, and transmit raw bytes of data between myself and these actual service providers (caveat: bad actors and modern infrastructure make "dumb pipe" transmission difficult if not impossible).

Par27(cont): In particular, the Commission should seek commentary from software engineers who work on products such as Google, Twitter, Facebook, and other modern web services and APIs. These engineers can comment on how versions of these products can be run entirely on localized networks without an ISP being involved (specifically, dev environments and staging environments, as useful jargon references). Because these services are provided without an ISP being involved, it is clear that said ISPs cannot be providing them, and thus using them as an argument that broadband internet service is an Information Service under Article 3 of the Act is incorrect.

Par28: I would disagree that users "rely" on the email service provided by their ISP, but consider it a distinction without a difference. I would agree that users rely on their ISP for DNS resolution, but disagree with the implication that ISPs are the only entities capable of providing such a service. It is possible, with minimal technical skill, to replace the IP addresses used for DNS resolution from those provided by one's ISP to a different entity (e.g., Google DNS https://developers.google.com/speed/public-dns/). In some cases, this may even improve the performance of one's internet connection as a whole. Regarding the question of whether a consumer is "capable of accessing these online services without Internet access service," see my comments on paragraph 27. In short, yes, it is entirely possible that a consumer could access such services via "point-to-point special access," although I am aware of no service which presently offers such special access (due, I suspect, to broad market forces around pricing, availability, demand, etc.).

Par29: Indeed, the infrastructure of the modern internet is convoluted and abstracted away from consumers, and yet nonetheless critical to their enjoyment of a performant service. While the user may type "facebook.com" into their browser's address bar and expect to see their grandma's vacation photos, regardless of what path that data takes, their applications which they connect to their internet connection (in particular their web browser) expects much more precise and uninterrupted transmission of data. Taking the same example, after receiving a user request for "facebook.com", the browser cannot yet send the HTTP request to fetch the page; instead, it must dereference the hostname into an IP address, perhaps by sending a point-to-point transmission from itself to 8.8.8.8 (Google DNS) to receive back the (example) IP 127.0.0.1 (this is still a further abstraction over the fact that the actual transmission is point-to-point from the user's IP to 8.8.8.8, and the user's IP may actually still be hidden behind firewalls, NAT layers, subnetworks, VPNs, etc.). Once the actual IP for "facebook.com" is received, the browser can then send another point-to-point transmission for a GET request to acquire grandma's vacation photos (and status updates, and friend updates, and etc etc etc in multiple rounds, each a different PtP transmission). The Commission also references caching servers -- there are two relevant cases of this. In one case, a third party such as Cloudfront allows a user (or their application of choice on their behalf, referred to hereafter as "the user" for brevity) to make a request for data from a more convenient physical location. Extending the example from before, the request to 127.0.0.1 may instruct the user to make a different request to 128.0.0.1 for the bytes of the photos themselves; 128.0.0.1 may in this case have been determined to be physical closer to the user and thus result in faster response time, or may have larger bandwidth available in order to prevent network saturation on 127.0.0.1; in either case, the ISP was not involved in the transmissions and simply carried them PtP as requested. In the second case, a third party such as Netflix may enter peering or colocation partnership with the user's ISP to store the third party's data on (or physically very near) the ISP's network infrastructure, so that when the user makes a request to 129.0.0.1 (Netflix's IP for this example), the ISP can recognize the request and "fake" a response from Netflix with the same information that would have been acquired by sending the actual request; such an arrangement is convenient for users, to be sure, but sets a very dangerous precendent for the market -- only established companies with enough funds or clout to buy/negotiate such peering agreements will be able to acquire them, a situation which will slow growth and innovation in the market in favor of consolidation of larger existing players. This may well be a case where consumers should be protected from something they want in order to preserve the freedom of the larger market.

Par30: Indeed, the infrastructure of the modern internet is complex and relies in some parts on not "literally" transmitting data as the user requests. This may be a case where direct analogy to telephone services fails, and Title II regulation may not be fully applicable as written, necessitating exemption or new regulation entirely.

Par32: I believe Section 231 has erred in its definition of "Internet Access Service" (IAS). Or, rather, that IAS and ISP have been conflated ("service" being used in both monikers is unfortunate). As point of example, I believe Section 231 would classify Google, Facebook, Twitter, Wikipedia, etc. as IASs, but exclude Comcast, Verizon, etc. as telecommunications services. (see reasonings above about the difference between providing PtP data transmission (ISP) and services which enable information services via the internet (IAS))

Par36: I cannot comment to advertisements in the past, but can say that present advertisements focus on speed (bits per second) and reliability (uptime) to the near (or total) exclusion of offerings that would be classified under an IAS (email, social media, etc.)

Par37: Without DNS, users would have to provide explicit IP addresses (eg 127.0.0.1 or 2001:0db8:85a3:0000:0000:8a2e:0370:7334, with possible abbreviations) instead of more human-memorable and human-readable URLs such as "facebook.com". This would be cumbersome, but not fundamentally change the user's interaction paradigm (further requests could be made by the browser-user on behalf of the human-user using raw IP addresses without the human-user knowing). Furthermore, DNS could be accomplished offline by caching locally a copy of all IP address resolutions and the consumer's interaction would not change at all (although this would be horribly inefficient). I cannot confidently comment on the impact of removing caching services.

Par44: I have not observed any change in provider investment in network expansion and innovation. Indeed, it is precisely as low and disappointing as it has been over the last decade or so. I would also comment that absent observed harm, Title II classification may be a prudent proactive step to avoid predicted future harm.

Par45: I take issue with the Commission's attempt to project neutrality in their analysis by making reference to opposing viewpoints/interpretations, but downplaying the apparent strength of said opposing points by relegating them to a footnote.

Par75: The Commission should consider a standard which prevents the holders of subsidiaries of ISPs from benefitting from anti-competitive practices on the part of the ISPs. A common example is not allowing Comcast (which owns several cable television channels) from enriching itself by using its ownership of Xfinity (an ISP) to throttle or degrade consumers' connections to Netflix (an independent media company) in order prevent losing customers from Comcast's cable media offerrings to Netflix's internet media offerings (a practice often referred to as "cord cutting")

Par80: Allowing ISPs to define "reasonable network management" (as the Commission seems to suggest) or waiting for court precedent to be set is a worrying position for consumers to be in. Allowing ISPs to define "reasonable" is a case "letting the fox guard the hen house" and is open for abuse. Waiting for court precedent is the usual way of things, but naturally leaves consumers in an uncertain position of not knowing whether their internet connection can be trusted to be free of (unreasonable) manipulation.

Par88: I have no comment except that I am glad that the Commission seems to agree with the spirit of the Rule.

Par92: The restriction should absolutely include a provision that "other business justifications" are not allowable justifications, so as to avoid harmful discriminatory and anti-consumer practices.