Privacy Public Policy

IP Addresses Are Not Telephone Numbers – The Fundamental Flaw with the FCC’s Proposed Privacy Rules

Last month the U.S. Federal Communications Commission (FCC) released a Notice of Proposed Rulemaking (NPRM) on Customer Proprietary Network Information (CPNI), the information telephone companies collect about consumers’ phone calls.

The Commission’s proposed rules would adapt and apply privacy rules to broadband providers that have historically applied to the traditional telephone carriers. It would also regulate how broadband providers use and share that data. The FCC is able to do this since broadband providers are now subject to the existing privacy protections under Title II of the Communications Act as a result of the Open Internet Order.

Providing consumers with the tools they need to protect their privacy is unquestionably a good thing. However, the Internet Society is concerned about whether expanding and applying Title II to the broadband market is the right approach, as such a course of action may have unintended consequences.

Of particular concern to the Internet Society is the following text taken from section 45 of the NPRM:

“45. Internet Protocol (IP) Addresses and Domain Name Information. We propose to consider both source and destination IP addresses as CPNI in the broadband context. An IP address is the routable address for each device on an IP network, and BIAS providers use the end user’s and edge provider’s IP addresses to route data traffic between them. As such, IP addresses are roughly analogous to telephone numbers in the voice telephony context, and the Commission has previously held telephone numbers dialed to be CPNI. Further, our CPNI rules for TRS providers recognize IP addresses as call data information. IP addresses are also frequently used in geo-location. As such, we believe that we should consider IP addresses to be “destination” and “location” information under Section 222(h)(1)(A). Similarly, we propose to consider other information in Internet layer protocol headers to be CPNI in the broadband context, because they may indicate the “type” and “amount of use” of a telecommunication service. We seek comment on this proposed interpretation.”

A blanket association between telephone numbers and IP numbers and domain names is not simply not useful. Here’s the problem – IP numbers and domain names are not telephone numbers. By using this analogy as the starting point for their rationale to consider IP numbers as CPNI, the FCC is beginning from a fundamentally flawed starting point.

The telephone numbering system was born out of an inherently regulatory framework within a multilateral institution, and coordinated at the international level by the International Telecommunication Union (ITU). In contrast, IP addressing was born out of a global, bottom-up multistakeholder approach. This model has been a driver of the innovation and creativity that made the Internet a virtually unparalleled force for social and economic progress in our collective history. Generally speaking, this broad comparison fails to account for the underlying context for each numbering system, and renders the analogy too broad and insufficient to be effective.

There may also be unintended negative outcomes globally from using this analogy. Like it or not, Washington exists in a policy fishbowl – the rest of the world pays attention to what happens here. There are nations that will watch, and may indeed copy, the FCC’s lead.

Applying decades-old telephone system regulations to the Internet puts at risk the principles and norms that contributed to its tremendous growth and success. As Dr. Robert Pepper wrote in Forbes ahead of the ITU’s World Conference on International Telecommunications in 2012, “Changing the regulatory and business model of the Internet now with an outdated legacy telecom model would limit the Internet’s expansion and diminish the potential for further innovation.” Pepper rightly concludes “This would be an enormous mistake.”

Furthermore, the FCC’s use of this analogy is in clear contrast to the deregulatory approach to the Internet that the U.S. Government promotes on the global stage. In a world where the multistakeholder model for Internet governance is so often under threat, do we really want the FCC to normalize a governance framework that does not recognize the crucial role of it played in the growth and success of the Internet?

The Communications Act was developed at a very different time and to regulate a very different system. Putting aside the fact that the Act dates from the 1930s, the last time it was updated was in 1996 – the dawn of the widely available Internet. I believe the distinctive nature of the Internet compels us to take an approach to consumer privacy that is just as unique.

Comments on the NPRM close tomorrow.

Building Trust Domain Name System Security Extensions (DNSSEC) Improving Technical Security IPv6 Open Internet Standards

Calling All Network Researchers – Call for Papers Opens for Applied Networking Research Workshop

We’re excited to announce the inaugural Applied Networking Research Workshop (ANRW) 2016, which will take place in Berlin on July 16. This one-day workshop will be co-sponsored by the Association for Computing Machinery (ACM), the Internet Society and the Internet Research Task Force (IRTF).

This academic workshop will provide a forum for researchers, vendors, network operators and the Internet standards community to present and discuss emerging results in applied networking research. Accepted papers will be published in the ACM Digital Library.

The ANRW ’16 particularly encourages the submission of results that could form the basis for future engineering work in the Internet Engineering Task Force (IETF), that could change operational Internet practices, that can help better specify Internet protocols, or that could influence further research and experimentation in the IRTF.

If you have some relevant work and would like to join us in Berlin for the workshop and potentially stay for the IETF 96 meeting that takes place in the following week, the submission deadline is May 16th.

The full Call for Papers includes detailed paper submission and formatting instructions.

I hope to see you in Berlin for what promises to be a very interesting workshop and a good warm-up for the IETF and IRTF meetings to follow.

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Events Internet Governance Public Policy To archive

Watch Live – Thursday, March 17 – Sally Wentworth Testifying at US Congressional Hearing on Privatizing IANA

On Thursday, March 17, 2016, our VP of Global Policy Development, Sally Shipman Wentworth, will be testifying before the U.S. Congress on the topic of “Privatizing the Internet Assigned Numbers Authority” (IANA) starting at 10:15am US EDT (UTC-4).  You can learn about the hearing at:

and watch live at:

Sally’s written testimony is available in advance from our site at:

and also from our general IANA stewardship transition page.

The hearing is before the Communications and Technology Subcommittee of the U.S. House of Representatives Energy and Commerce Committee. The speakers as of now will be:

  • Dr. Alissa Cooper, Chair, IANA Stewardship Transition Coordination Group
  • Mr. Steve DelBianco, Executive Director, NetChoice
  • The Honorable David A. Gross, Former U.S. Coordinator, International Communications and Informational Policy, Wiley Rein LLP
  • Ms. Audrey Plonk, Director, Global Security and Internet Governance Policy, Intel Corporation
  • Mr. Matthew Shears, Representative and Director, Global Internet Policy and Human Rights Project, Center for Democracy and Technology (CDT)
  • Ms. Sally Shipman Wentworth, Vice President, Global Policy Development, Internet Society

Please see our IANA Stewardship Transition page for more background information. The video stream will be recorded if you are unable to watch the session live.

Community Projects Domain Name System Security Extensions (DNSSEC) Events Improving Technical Security IPv6 Open Internet Standards Privacy

INET Trinidad & Tobago Covers IPv6, DNSSEC, Privacy, IXPs, CyberSecurity, and More This Week

This week, we are organizing INET Trinidad & Tobago, on 8-9 October 2014. The Telecommunications Authority of Trinidad & Tobago (TATT), which is the local telecoms and broadcasting regulator, is hosting this event. INET is the brand name that the Internet Society uses for its events that deal with wider Internet-related topics. INETs can be locally, regionally, or even globally focused. This INET is to get the local community acquainted with Internet challenges and how to be engaged with addressing these challenges.

The world is changing and we know that the only constant is change. The Internet is challenging traditional telecoms, which is why all stakeholders need to be acquainted with the opportunities that the Internet brings. In addition to opportunities, there are challenges and this is exactly where this INET comes into play.

Cyber security is a big challenge in the Caribbean. Governments, policymakers, the business community, academia, and civil society all need to work together to achieve the best results in a given situation.

INET Trinidad & Tobago will focus on some key technical and policy areas including:

  • IP numbering (IPv4 depletion, IPv6 adoption)
  • RPKI
  • Net neutrality
  • OTT
  • The future of the Internet
  • Cyber security
  • IXPs
  • Identity and Privacy
  • ccTLD management
  • Local Internet content development

From the Internet Society, experts such as Raul Echeberria, Jane Coffin, Sebastian Bellagamba, Christian O’Flaherty, Christine Runnegar, and Shernon Osepa will be participating.

In addition to the Internet Society’s presenters, some key Caribbean experts such as Bernadette Lewis (CTU), Regenie Fraser (CANTO), Bevil Wooding (PCH), Brent McIntosh (IPv6 Forum Grenada), Kurleigh Prescod (Columbus Communications), Dr. Patrick Hosein (UWI) will be presenting as well.

The event will be webcast live here on both days. We hope you will tune in online or join us in person!

Growing the Internet IPv6

Internet Growth and Competition Requires More IPv6 Content

Wired are running a mini-series on the hot topic of net neutrality this week and their first installment is a useful overview of the issues. I could take issue with some of the points raised in that article, but here I’d like to focus on the conclusion that, ‘One way to prevent [an unfair playing field for Internet services] is through greater competition among ISPs.’

Even supposing there was wider agreement that more competition could help, it’s going to be hard for new entrants to the ISP business to get a foothold as the IPv4 addresses needed to connect subscribers to the Internet are close to being gone. The American Registry for Internet Numbers (ARIN) in North America has fewer than 16 million IPv4 addresses left to allocate to new or existing ISPs and it is predicted that ARIN will run out of IPv4 addresses in less than eight months. Once ARIN is out, only 1 of the 5 global Internet number resource registries (AfriNIC, in Africa) will have any remaining IPv4 address space.

There is a solution to this seeming impasse, however. If more Internet content providers followed the lead of companies like Google, Facebook and Yahoo! in making their content available over IPv6, new entrants to the ISP marketplace wouldn’t need to worry so much about getting IPv4 resources to assign to their customers. As more content becomes available over IPv6, ISPs can more reliably deliver IPv4 connectivity via translation tools. Some mobile ISPs are already running in IPv6-only operation, demonstrating the viability of this approach.

The World IPv6 Launch initiative is reporting monthly on the growing number of major ISPs rolling out IPv6 connectivity to their subscribers around the world. There is a now a clear and compelling case that it is content providers that must do more to help deploy an Internet platform based on IPv6 that can cater for growing levels of competition and innovation at all levels of the stack.

Events IPv6

Attending the Big Telecom Event This Week? Talk to Us!

Where are the telecom giants on their paths to full IPv6 adoption? This week (on 17-18 June) we’ll be at the Big Telecom Event in Chicago trying to answer that question.

We’ll have booth PP503 in the ‘demo space,’ so I hope you’ll stop by and say hello. We’ll be talking to attendees about the Internet Society and its technical programs and about technologies that are important for the future health and growth of the Internet, including my favorite topic, IPv6.

We’ve just celebrated the two year “Launchiversary” of World IPv6 Launch, LACNIC has become the third of five Regional Internet Registries to run out of IPv4 address space, and more and more organizations are publicly calling for more IPv6 deployment. We hope that this event brings together telecom companies of all sizes and in all phases of their own deployments for real discussion about the best path forward – for the telecom companies and the millions of users they support.

We hope to see you there.


IPv4 is Really Almost Out – The Time for IPv6 is NOW

On our Deploy360 blog we’ve been documenting the exhaustion of IPv4 addresses in each of the regional registry pools around the world. Yesterday, LACNIC announced that practically speaking there are no more IPv4 addresses available in Latin America and the Caribbean. What this actually means as we documented on our Deploy360 site is that they are down to the final 25% of their last /8 allocation, and are now in a mode of operation where allocations are far more limited and review of applications for new addresses is much more restrictive. It is starting to become impossible to get IPv4 address space using the traditional means around the globe.

As LACNIC CEO Raul Echebarria pointed out, the need for network operators to transition to IPv6 has never been more urgent. There is plenty of IPv6 address space available for anyone who wants to use it and there is more and more IPv6 being deployed in networks around the world. As we document on the World IPv6 Launch site each month, the number of networks with measurable IPv6 deployment continues to increase, and the amount of traffic from those networks to big websites around the world increases steadily as well. It is worthwhile mentioning that the most popular websites – Google, Facebook, YouTube, Yahoo!, and Wikipedia – have been using IPv6 for a couple of years now. We also observed that networks that have IPv6 deployed for their end users see a lot of IPv6 traffic on their network.

Transitioning to IPv6 is very possible and the exhaustion of IPv4 addresses in the LACNIC region just provides us with one more reminder that now is the time to make the transition. Our Deploy360 Programme can help you get started.