Public Knowledge has the pleasure of inviting you to a multifaceted program focused on training and developing the next generation of tech policy experts and public interest advocates that reflects the diversity of voices and experiences in our society. Please join us for our monthly Career Breakfast Series. This event is designed for students & recent graduates to learn about tech policy and public interest work, careers, and its community. This month you will have the opportunity of having a great conversation with Adam Conner.

Adam is the Vice President for Technology Policy at Center for American Progress. He leads the newly created Technology Policy team as its inaugural vice president with a focus on building a progressive technology policy platform and agenda.

Adam has spent the past 15 years working at the intersection of technology, politics, policy, and elections as the first Washington, D.C., employee for several Silicon Valley companies. He was a spring 2018 resident fellow at the Harvard University Institute of Politics, where he led a study group titled, “Platforms, Networks, and New Power Technology’s Impact on Politics, Policy, and Elections,” which focused on the rise of technology companies and their effect on politics and democracy.

Most recently, Conner was the first Washington employee for Slack Technologies, the fast-growing workplace communications startup, leading their engagement with federal, state, and local governments. Prior to that, Conner was vice president of Brigade, a civic engagement platform co-founded by Sean Parker. In 2007, Conner founded Facebook’s Washington office. He spent seven years on the Facebook Privacy and Public Policy team, where he created the company’s government and political outreach efforts and directed the company’s election efforts. His congressional and campaign experience includes the U.S. House Committee on Rules, former Gov. Mark Warner’s (D-VA) Forward Together PAC, and John Kerry’s 2004 presidential campaign.

Conner is a graduate of George Washington University’s School of Media and Public Affairs and serves on the university’s board of trustees. He hails from Los Alamos, New Mexico.

Join us on Friday, July 7 @ 08:00 A.M. ET at The Gathering Spot in Washington, D.C.

This is a private event. However, if you know someone that would be interested in attending, please email michele@publicknowledge.org

The post Privileged Conversations | July 2023 appeared first on Public Knowledge.

The post Privileged Conversations | June 2023 appeared first on Public Knowledge.

Today, President Joe Biden nominated Anna Gomez for Commissioner at the Federal Communications Commission.

Ms. Gomez has spent the bulk of her career serving the public interest at the FCC and at the National Telecommunications and Information Administration. She currently serves as the Senior Advisor for International Information and Communications Policy at the U.S. Department of State. She previously served as the Deputy Assistant Secretary for Communications and Information at the NTIA. She has also served at the FCC as the Deputy Bureau Chief of the International Bureau and worked in the Wireline Bureau and for former Chairman Bill Kennard. In those roles, she gained a depth of knowledge and experience on telecommunications and technology issues. Public Knowledge expects Ms. Gomez to support Chair Rosenworcel and the administration’s stated goals for broadband authority and oversight at the FCC, including net neutrality, universal service, affordable broadband access, and broader public interest protections.

The following can be attributed to Chris Lewis, President and CEO at Public Knowledge:

“For far too long, the Biden administration and Senate leaders have left us without a full, five-person FCC while important issues are in front of the agency. Anna Gomez has deep, demonstrated experience working for the public on telecommunications and technology issues. Her decades of experience in the telecommunications sector, most of those spent serving the public interest, will allow Ms. Gomez to get right to work at the FCC, which is critical to help the FCC move forward with its agenda of ensuring all people have access to communications services. Her work for the FCC and the NTIA will be beneficial as the administration and Congress increasingly look towards these two agencies to coordinate efforts to close the digital divide.

“As with any nominee, we expect Ms. Gomez’s confirmation process will help shed more light on her specific views on the issues and we look forward to learning more about those and how she would approach her role as a Commissioner. We urge the Senate to move quickly on her nomination as there is much important and pressing work before the FCC that will require a full Commission to accomplish.”

The post Public Knowledge Welcomes Nomination of Anna Gomez as FCC Commissioner appeared first on Public Knowledge.

Today, the U.S. Supreme Court announced its decision in Gonzalez v. Google. The Court found that, because the plaintiffs would not be able to establish liability even without Section 230’s protections, there was no reason to consider the case further.

Public Knowledge previously filed a brief in this case, arguing that content recommendations are shielded by Section 230, and that only Congress should update the law in a way that furthers 230’s goals of free expression and competition, while limiting the spread of online harms. 

The following can be attributed to John Bergmayer, Legal Director at Public Knowledge:

“It often gets lost in discussions of Section 230 that it is only a liability shield. Even without Section 230, plaintiffs still have to state a plausible legal claim. Here, they did not, and the Supreme Court saw no reason to go further than that.

“Congress should take note. Over the past several years, we have seen repeated legislative proposals that would remove Section 230 protections for various platform activities, such as content moderation decisions. But those activities are fully protected by the First Amendment, and removing Section 230 would at most allow plaintiffs to waste time and money in court, before their inevitable loss.  

“By cutting off frivolous legal claims at an earlier stage in litigation, Section 230 does not only save both plaintiffs and defendants time and money, but also promotes free expression by allowing platforms to host user speech and to moderate content according to their individual policies. This is especially valuable for smaller platforms that cannot afford the expense of constant litigation.

“Many complaints about Section 230 and content moderation policies amount to concerns about competition and the outsize influence of major platforms. These concerns are valid, but unrelated to Section 230. The route to addressing concerns about the role of dominant technology platforms in our lives is not through weakening Section 230, which is essential for large and small platforms alike. Without Section 230, no new competitor is likely to arise to challenge the dominance of Google, Meta, or Twitter. Policymakers should focus their attention on addressing the power of these platforms through new laws to strengthen antitrust and promote competition against the largest platforms.”

You may view the amicus brief for more information on this case.

The post Supreme Court Decision in <em>Gonzalez</em> Confirms Section 230’s Value in Promoting Free Expression appeared first on Public Knowledge.

Today, the Federal Communications Commission voted to approve a Report and Order and Further Notice of Proposed Rulemaking that will consider potentially opening 1000 MHz of spectrum to new commercial uses. 

The Order declines to adopt a proposal from January 2021 to open the 12.2-12.7 GHz band for mobile use out of concern that this would cause harmful interference to existing satellite services such as DirecTV and Starlink. However, in the Further Notice of Proposed Rulemaking, the FCC considers other possible ways to expand use of the 12.2-12.7 GHz band, such as permitting unlicensed operations to support next-generation Wi-Fi or authorizing fixed wireless broadband services. In addition, the FCC proposes to clear a portion of the 12.7-13.25 GHz band for mobile broadband, but also seeks comment on whether to authorize unlicensed operation or other forms of access in this portion of the band as well.

Public Knowledge supported the original proposal to allow mobile in the lower band, but also asked the FCC to consider authorizing unlicensed or other uses of the band as well. Public Knowledge also previously supported opening the upper portion of the band for unlicensed or other new uses to support next-generation Wi-Fi and provide new wireless services for rural communities and Native Tribes.

The following can be attributed to Harold Feld, Senior Vice President at Public Knowledge:

“Although we had hoped the engineering would support opening the lower band for mobile use to enhance mobile competition, we respect the FCC’s engineering analysis. We have always said the science must lead, and the FCC has done a thorough and conscientious job. 

“By the same token, we are pleased that the FCC will continue to look at ways to make this spectrum more productive. There are many ways this spectrum can help to bridge the digital divide, promote innovation, and encourage deployment of new services and new technologies. Opening this band for unlicensed use would provide the spectrum needed for Wi-Fi 7, which will provide gigabit speed for connected devices. Authorizing fixed wireless broadband could provide rural communities with an affordable high-speed solution and promote competition against cable in urban areas. 

“Finally, we applaud the FCC for seeking comment on how its policies can contribute to promoting digital inclusion. We will strongly urge the FCC to consider giving Native American Tribes the opportunity to apply for any licenses authorized – whether for mobile in the upper band or for fixed wireless in the lower band – so they can continue to build their own broadband networks in some of the least connected communities in the country.”

The post Public Knowledge Applauds FCC Vote To Find More Spectrum for Digital Inclusion appeared first on Public Knowledge.

Progress in artificial intelligence seems to be something that happens, to paraphrase Ernest Hemingway, in two ways: gradually, then suddenly. A slow trickle of developments as well as surprising bursts of astonishing new capabilities have characterized the AI news cycle for as long as it has existed.

The latest burst of sudden developments relates to generative AI, or GAI — machine learning systems that are capable of outputting new material. GAI is a broad and descriptive term about what the system does, not a particular technology or approach to AI system design. GAI is being used to produce writing, conversation, art, music, video, and more. Systems like these have existed for years, developing gradually, but suddenly systems like ChatGPT, Stable Diffusion, and Midjourney are producing remarkably high-quality content that rivals human work.

We now need to develop policies to ensure that the benefits of these new technologies are broadly and equitably shared, while protecting the existing openness and vitality of the internet and our creative communities.

Unlike existing discriminative AI systems (those that analyze, sort, and process data), GAI raises unique concerns, especially about how human work, including the work used in training datasets, is recognized and valued. For photographers, visual artists, and musicians — especially freelance and independent creators who already struggle with economic precarity — the prospect of a flood of AI-generated content that rivals their work represents real economic risk. The people on the front lines of this disruption right now are artists and musicians, but thanks to large language models like ChatGPT, Sydney, and Bard, this wave of change could soon extend to many kinds of knowledge workers — especially if LLMs’ ability to go beyond simple text generation towards acting as independent agents continues to develop.

Concern regarding this disruption has people casting about for solutions to slow, mitigate, or prevent the potential harms of AI systems. One approach that is being considered — and litigated in two high-profile cases (see Andersen v. Stability AI and Getty Images v. Stability AI) — is how to apply the United States’ existing copyright system to limit GAI systems. 

This could be a disastrous mistake. Applying our existing copyright laws to our best understanding of GAI systems leads to the conclusion that while this technology is new, and there may be flaws in design and execution that create instances of copyright infringement, its core elements and essential ideas do not run afoul of copyright law. Most importantly, reinterpreting or expanding copyright specifically to use it as a bludgeon against GAI will instead threaten the openness and accessibility of the internet, throw up barriers to creativity, and primarily benefit the biggest publishers, distributors, and content creators while leaving small and independent creators to struggle with economic precarity and disruption.

Many artists, creators, and consumers have already adopted stances on GAI ranging from skepticism to outrage. It is thus not enough to merely state the above conclusions; they must be backed up with informed and accessible public analysis that breaks down the copyright law, technology, and implications of proposed solutions. 

Let’s start with copyright. Copyright is not a magic spell that can be invoked anytime someone interacts with a creative work; it is actually a bundle of specific, enumerated (and limited) rights. These rights vary slightly based on the nature of the work, but generally include the rights to control the reproduction, distribution, and public display of the work, as well as to authorize derivative works. Copyright only grants the holder the legal ability to defend those specific rights, and is further limited by other legal doctrines like “de minimis” usage (meaning so little of a work was used that there is no infringement) or fair use.

Turning to the technology, it is useful to analyze the copyright issues related to GAI systems in terms of inputs and outputs. The GAI systems have three inputs: the training datasets; the training process that creates the machine learning model; and user inputs including text prompts, uploaded images, or other user-uploaded or linked reference material. From all of those inputs, the GAI system generates an output: text, images, audio, video, and so on.

Input #1: The Training Data

GAI systems are built on huge datasets. These vast swathes of data are used for training the machine learning models because more data results in more useful, well-rounded models; the more data the system can learn from, the better it gets. Most GAI systems use training datasets assembled through the crawling and scraping of the publicly accessible internet. 

This isn’t a new practice or novel legal issue. Instances of commercial web crawling have been challenged — and consistently found permissible — under the Computer Fraud and Abuse Act. That’s because commercial web crawling is largely geared toward the collection of data and statistics, not the full copyrighted content of a website, so commercial web scrapers tend to avoid infringing the reproduction right of the copyright holders. In other instances, building large digital datasets of copyrighted material is unavoidable for the functionality of a project. A good example of this is the Google Books project and internet search more broadly. Google Books specifically came under fire from authors, publishers, artists, and photographers over the digitization and display of copyrighted content. The project was ultimately found to be a fair use that promotes copyright law’s very purpose: to expand public knowledge and understanding. 

The datasets on which GAI systems like ChatGPT and Stable Diffusion rely are more like Google Books than commercial web crawlers that gather data; GAI systems need writing and art in its complete form to train from. And the comparison to Google Books doesn’t stop there.  Many GAI systems are built using third-party public datasets like Common Crawl and LAION that are distributed under fair use principles and provide a real public good: archiving and making accessible the aggregated content of the internet for academics, researchers, and anyone else that may want it. These are free, non-commercial datasets collected by nonprofit organizations for use by researchers and the public. Web crawling and scraping also underlie the operation of search engines and archiving projects like the Internet Archive’s popular Wayback Machine. 

In other words, the same practices that go into collecting data for GAI training are currently understood to be non-infringing or protected by fair use. Considering how vital these practices are for an open and accessible internet, we should ensure that they stay that way.

Input #2: The Training Process

As a threshold matter, it is critical to understand that accessing, linking to, or interacting with digital information does not infringe any copyright. Reading a book, looking at a photograph, admiring a painting, or listening to music is not, and never should be, copyright infringement. This is not a “fair use” issue; the ability to use, access, or interact with a creative work is outside a copyright owner’s scope of control. Based on the best explanations of how GAI systems work, training a GAI system is generally analogous to these kinds of uses.

A GAI model does not contain an archive or directory of the works it trains on that the system queries, searches, or references. Rather, during training the system processes the work, deconstructing it using math to learn from it. To vastly oversimplify, this learning takes the form of building and modifying the strength of connections between a model of datapoints, resulting in a collection of mathematical weights that define the model. The work being analyzed is not reproduced or stored in the model; instead, the model uses each work to improve its overall understanding of whatever it is training on (art, photographs, writing, and so on).

In Andersen v. Stability AI,  the class action lawsuit against Midjourney and Stable Diffusion (two of the most widely used GAI art systems), the plaintiffs conceptualize the training process differently. They characterize the training process as a mechanism for storing the training images in a compressed state. Ultimately, this interpretation will be tested in litigation, but the generalization process that training images go through does not result in any conventional kind of storage. 

There are two facts that make this apparent. First, in an ideal model, none of the content used in training can be reproduced by the system with any reliable fidelity. Second, the simple reality of the quantity of information these systems are trained on, compared to the size of the models themselves, should make that obvious. One can download the fully trained Stable Diffusion model weights at the size of 4 GB, while the LAION-2B dataset it is trained on — the smallest version — contains around 80,000 GB of images; no amount of compression would allow for the model to contain all that information. Simply put, the model does not contain its training data within it. 

The best understanding of the technology therefore points to the model (in its own way) really learning from training images and not merely reproducing and storing them in compressed or abstract mathematical form. Of course, this evaluation relies on information about a highly technical, insular, and rapidly developing field of study. It might be the case that the architecture of the existing or future systems is different from what is described here, but either way, the essence of the training process itself does not involve infringement of copyrighted work.

Input #3: User Inputs

From a copyright liability perspective for GAI systems, user inputs are not a real concern. Naturally, users can misuse tools, even existing ones like image editing software, to infringe copyright or get up to other mischief, but that does not make the tool infringing. And the user inputs themselves, divorced from the outputs they may produce, do not violate any of the bundle of rights that copyright holders can claim. Even if a user were to feed copyrighted content into a GAI system as a prompt or priming material, this is merely use—not reproduction or distribution. In addition, while the outputs of GAI systems are not protected by Section 230, a user’s inputs to a GAI system certainly are.

Output: The Generated Content

GAI systems are defined by their outputs. The writing, images, and other content that they produce raise a collection of copyright-related concerns. These concerns can be distilled to a single question: Do the outputs of GAI systems pass the “substantial similarity” test to not qualify as reproductions, and if they do, do they still incorporate enough major copyrightable elements from existing works such that the output could be characterized as an unauthorized derivative work?

Image-generating diffusion models in particular suffer from “overfitting” and “memorization.” When a specific work appears in similar form many times throughout a training dataset, that image’s combination of characteristics can become overly well-connected in the model. The result is sometimes called “memorization” because the model is able to output a fairly good copy of that work if prompted to. This is an example of “overfitting” in training — where a model cleaves too closely to its training data instead of being able to generalize from its training. These overfit outputs, depending on their quality, can and should be considered infringing reproductions. While this may seem fatal, it is ultimately a red herring. Generalization is the ultimate design goal of these systems, and instances of memorization and overfitting — which raise copyright alarm bells — are essentially bugs, not features. After all, finding a copy of something that already exists online is a simple matter of search; the value of a GAI system is that it makes something new.

Relatedly, some might argue that since GAI systems are trained on copyrighted material and lack human agency and creativity, that all of the outputs are derivative works. A derivative work is a new work that is based on an original work, and shares major copyrightable elements with the original, but which has its own copyright protection because of the new elements in the work. But this is where the ability of these systems to genuinely generalize is the critical factor. When the model is training on, for example, a portrait, it is learning general compositional information about portraits, faces, and so forth. So when a user prompts it to produce a specific kind of portrait, it isn’t pulling from any work or works specifically, but from its whole corpus of training, so none of the works in the training data are original works for the purpose of a derivative works analysis. Put another way, in a well-generalized model, the influence of any one work in the training set should be regarded under the de minimis doctrine as insignificant in its overall contribution to the new work.

Another narrative echoing across creative communities is concern about the ability of a GAI system to produce new works in an artist’s style. Generally, copyright law doesn’t protect style, ideas, or concepts. For a work to be an infringing reproduction, there must be substantial similarity between two specific works in terms of expressive content. That means that a work just having a similar vibe, style, characteristics, or subject matter is not infringement. Another angle from which to approach the issue of style is that copyright holders have the right to control derivative works. The copyrightability of work created using GAI is a whole separate issue, so, the only element of the doctrine that is relevant here is whether some works produced using GAI systems pass the “substantial similarity” test to not qualify as reproductions, but still incorporate enough major copyrightable elements from an existing work such that the output could be characterized as an unauthorized derivative work. So, again, it cannot be a matter of similar style, subject matter, or general features — there must be specifically identifiable elements from particular works — and that still doesn’t describe the situation artists are worried about with GAI producing new works in existing styles.

In light of the threat of competition from these machines, and the value we have for art, there may be a temptation to deviate from the established copyright canon and expand the notion of what can be protected, but this is a dangerous idea.

All creative work is the product of a process of copying, transforming, and combining our experiences, inspirations, and influences. Every form of art, culture, and invention is rife with examples of celebrated works that reimagines, riffs on, or downright knocks off existing work. No one can, or should be able to, enforce a copyright on the basis of style, concept, or feeling alone. It is the free exchange of ideas and inspirations, and the ability to reimagine and remix existing work, that allows artists to build on existing ideas and push creative boundaries. Trying to enforce copyright protection on styles or ideas would short-circuit the creative process and stifle artistic development.

And while some small and independent creators are on the frontlines of the fight against GAI right now, it is important to remember that there are, and always have been, significant inequalities in what work is valued, whose work is respected, and who will have the power and resources to aggressively defend their work. For instance, hip-hop music was initially criticized for its use of sampling from other artists’ work and faced repeated copyright challenges which restricted the right of artists to use samples without paying for licenses. Anti-sampling cases resulting in mandatory licensing transformed a counter-cultural, democratized, method of making art into yet another tool that only established artists and record labels could leverage. Today, underground hip-hop artists using uncleared samples and mashup artists still find themselves locked out of key revenue streams like streaming platforms because of these restrictive copyright rules. 

There are obvious parallels between sampling and artists using GAI tools today, but even artists working traditionally ought to consider how existing industry power dynamics would play out if there were vastly expanded “stylistic” copyright rules. Record labels, music studios, and established artists would have the resources and power to go after any creator that encroached on their “style,” potentially locking up whole genres and aesthetics behind licensing structures. Reducing every shred of human originality to copyrightable units that must be bought and sold is a far greater threat to creativity than new automated tools will ever be.

Expanding Copyright Law Won’t Protect Artists from GAI’s Disruption

Copyright is enshrined in the Constitution with the phrase: “To promote the progress of science and useful arts…” Taking that purpose seriously, it should be clear that copyright and GAI should not be set at odds with one another. Like the internet — another disruptive technology that forced us to grapple with copyright concerns — GAI is rich with possibilities for redrawing the lines of creativity, productivity, and prosperity. 

This is not to say that there aren’t challenges: Overfitted, infringing reproductions of existing works and concerns about how to navigate consent, credit, and compensation for creators are uncannily reminiscent of early concerns about file sharing and web search indexing. Indeed, to some extent, these concerns about the internet have always lingered and are now crossing over and combining with concerns about GAI. But, as the Copyright Office already determined when it recommended against creating special ancillary copyrights for news content, even when there are serious concerns about the future of important human activities, expansions of copyright aren’t necessarily the effective solution — and would necessarily mean limiting fair use and free expression. 

This impulse to expand or redefine copyright law to allow others to control the ability to use, access, interact, and learn from creative works cannot be the solution to these fears. If we lose the right to freely use and enjoy creative works, we open the way for a new world of extreme commercialization where artists must pay for the privilege to create, and people find the costs and barriers to information and culture rising ever upwards. Generative AI presents the possibility of disruption — let’s embrace this opportunity for change by finding solutions that enhance the ability to create freely, transform traditional economic structures to ensure prosperity, and lower the barriers to enjoying the fruits of our diverse and vibrant shared culture.

The post <strong>Generative AI is Disruptive, But More Copyright Isn’t the Answer.</strong> appeared first on Public Knowledge.

Public Knowledge Director of Government Affairs Greg Guice will testify before the U.S. Senate Commerce Subcommittee on Communications, Media, and Broadband Thursday, May 11 at 10:00 a.m. His testimony in the hearing on “The State of Universal Service” will urge Congress to help the universal service mission evolve to meet the new connectivity challenges we face as a nation.

The testimony will also argue that both Congress and the Federal Communications Commission play an important role in closing the digital divide. As the testimony explains, contribution reform is essential to achieving universal service by providing access to affordable, ubiquitous broadband no matter where people live or how much money they make.

The following is an excerpt from the testimony:

“[Over the last few years,] Congress rightly determined that funding to ensure not only broadband access to promote deployment in rural and Tribal communities was important, but also that broadband affordability was critical because broadband is an essential service. Congress also [recently] included one-time support for digital equity to ensure that individuals and communities have the skills to fully participate in the digital economy.

“As we move to the [implementation] phase [for] broadband funding provided by Congress, now is the right time to think about the current state of the universal service program; the interplay between the Congressional funding and USF; and what that might mean for potential reforms. Public Knowledge [testimony] will focus on three areas:

“The Affordable Connectivity Program has demonstrated how a well crafted program focused on [helping] low-income families get connected. With 17 million families enrolled, it is a huge success. The USF equivalent program, Lifeline, does not come close to that level of adoption. The FCC should consider structural changes to the Lifeline program to ensure that it is better serving low-income families.

“The historic investment and support Congress recently made in broadband deployment will help promote the deployment of robust broadband across the country. The USF equivalent program, the High-Cost program, provides support for costs associated with initial deployment (cap expenditures or capex) and the ongoing costs of maintaining and upgrading networks (operating expenses or opex). Savings from the reduction in capex could be used to support funding for hardening networks to make them more resilient against ever-increasing natural disasters.

“[Finally], all of this depends on stability in the funding base for USF. [O]ur universal service program is seeing a decline in the communications revenues it relies on to advance this critical mission. That fact alone should be enough to demonstrate the contribution mechanism is broken. If we do not fix the contribution mechanism, “preserving and advancing universal service” as Congress has directed is an infinitely harder task. Closing the digital divide is not a one-and-done effort; it takes ongoing work and that work is the work of the USF.”

You may view the testimony. View our recent blog post, “The Time for Can-Kicking Has Passed: Fix Universal Service Contribution Now,” for more information on USF.

The post Public Knowledge Government Affairs Director Greg Guice To Testify Before Senate Commerce Subcommittee on Universal Service appeared first on Public Knowledge.

This week, Public Knowledge joined the United Church of Christ Media Justice Ministry in filing comments in the Federal Communications Commission’s proceeding to begin implementing the “Martha Wright-Reed Just and Reasonable Communications Act of 2022” to end predatory pricing for calls to and from incarcerated people.

The agency specifically seeks comment on how to interpret the Act’s language to ensure just and reasonable rates and charges for incarcerated people’s audio and video communications. The move follows almost 20 years of public interest advocacy championing the needs of this vulnerable group. UCC Media Justice and Public Knowledge urge the Commission to recognize the dysfunctional and consolidated market for carceral communications, interpret the new “just and reasonable” standard to exclude site commissions, and to reject calls that “fairly compensated” requires an increase in rates.

The following can be attributed to Al Kramer, Senior Fellow at Public Knowledge:

“Everyone has a right to connect with loved ones at reasonable prices. Unconscionable phone rates impose undue hardship on many families, forcing them to choose between connecting with incarcerated loved ones or putting food on the table. No one should ever have to make that choice. By enacting this law, Congress has made it clear that the FCC has jurisdiction over both interstate and intrastate rates and it expects the FCC to adopt lower rates for these calls. We look forward to the Commission’s efforts to keep incarcerated people connected and commend the agency for moving quickly to get this proceeding underway.”

You may view the comments for more information. Public Knowledge also joined the Benton Institute for Broadband and Society and the Prison Policy Initiative in additional comments on this proceeding, arguing for using average cost data for the industry as the basis for setting the maximum call rate for both phone and video communications.

The post <strong>Public Knowledge Files Comments Urging FCC To Help Keep Incarcerated People Connected</strong> appeared first on Public Knowledge.

The IP3 Awards, hosted annually by Public Knowledge, recognize individuals who have made significant contributions in the three areas of “IP”: Intellectual Property, Information Policy, and Internet Protocol.

Our 20th IP3 Awards ceremony will take place on September 28, and we’re currently accepting nominations for deserving candidates. Whether it’s for a career’s worth of work or a recent achievement, if you know someone who has excelled in any of these three fields, please nominate them!

To submit a nomination, simply fill out the form below by June 2, providing the nominee’s name and a brief explanation of why you believe they should win. 

Check out our past winners for inspiration. 

After receiving all nominations, a panel of judges will review the submissions and select three winners.

The post Nominations | IP3 Awards 2023 appeared first on Public Knowledge.

Today, the 11th U.S. Circuit Court of Appeals announced its opinion in Apple, Inc. v. Corellium, LLC, finding that copying functional software like iOS is a fair use. Specifically, it found that Correllium’s use of iOS code was transformative; that iOS itself is “largely functional” and farther from the core purpose of copyright than traditionally creative works; that the volume and scope of Correllium’s borrowing was necessary to achieve its transformative purpose; and that there was no measurable market harm to Apple’s market for iOS devices. 

Correllium uses portions of iOS code to make a “virtual environment” for security researchers to study and test vulnerabilities in iOS-enabled devices. Apple has argued that Correllium’s unlicensed use of iOS code is unlawful copyright infringement. Public Knowledge previously joined the Electronic Frontier Foundation and expert security researchers on an amicus brief in this case, arguing that Corellium’s copying of iOS was, in fact, a fair use.

The following can be attributed to Meredith Rose, Senior Policy Counsel at Public Knowledge:

“Today’s ruling represents a victory for both security and fair use. It is well-established in copyright law that protected works can be used, in their entirety if necessary, for the purposes of criticism, commentary, and other ‘transformative’ uses. The 11th Circuit rightly agreed that ‘largely functional’ software such as iOS can be used to create new and valuable tools without running afoul of copyright law. Independent security research — especially regarding systems in wide use, such as iOS — is absolutely crucial, and this kind of borrowing and transformation is what allows it to happen.”

You may view the amicus brief. For more information on why we support Corellium’s use of iOS software for security research, you may also view our recent blog post, “Apple v. Corellium Demonstrates a Clear Example of Fair Use.”

The post Eleventh Circuit Finds Corellium’s Copying of iOS as Fair Use in Victory for Security Researchers appeared first on Public Knowledge.

Recently, Senator Dick Durbin (D-IL) introduced the “Strengthening Transparency and Obligation to Protect Children Suffering from Abuse and Mistreatment Act of 2023” (STOP CSAM Act), a bill intended to provide additional, valuable protections for victims of online child sexual exploitation. The bill makes changes to the criminal code and improves some reporting requirements in regard to CSAM, but it also contains provisions that would strongly disincentivize digital platforms from designing their systems securely with end-to-end encryption. “EARN IT Act,” a bill that aims to increase the liability of platforms with respect to unlawful child abuse material but that would also harm user security and privacy, was previously scheduled for a markup with STOP CSAM Act and will likely be scheduled for the same markup soon.

The STOP CSAM Act would subject platforms to civil liability under a knowledge standard that is so low that simply being aware that a service can be used for CSAM, including by being enabled through the use of end-to-end encryption, would likely be enough for litigation to be initiated. By discouraging the use of end-to-end encryption, the bill will weaken the privacy and security of everyday communication services without any net benefit to public safety or the protection of the victims of CSAM. These and other concerns with the STOP CSAM Act are highlighted by Public Knowledge in its updated Section 230 reform scorecard for the 118th Congress.

The following can be attributed to Lisa Macpherson, Senior Policy Analyst at Public Knowledge:

“Congress should absolutely act to curb the scourge of child exploitation online. Changes to the law, including STOP CSAM’s improved reporting system, accompanied by increases in 

funding for law enforcement and victim assistance, could provide valuable support for victims of online child sexual exploitation. However, the provisions that encourage monitoring of all users’ private communications and data, and those that discourage end-to-end encryption, as well as the use of Section 230 carve-outs to enforce greater transparency and accountability by digital platforms, fail our principles for protecting free expression online. We urge Congress to abandon those provisions, as they jeopardize the privacy and safety that encryption ensures for all users of digital communications services.” 

You may view our principles to ensure that any Section 230 reform still protects free expression online – a test STOP CSAM Act clearly fails in our Section 230 scorecard for the 118th Congress.

The post Public Knowledge Urges Congress To Reconsider Child Protection Bill Provisions Risking Platform Security, Encryption appeared first on Public Knowledge.

Recently, Senators Lindsey Graham (R-SC), Richard Blumenthal (D-CT), and others reintroduced the “EARN IT Act” to increase the liability of platforms with respect to unlawful child abuse material. Platforms that knowingly carry such material can already be held criminally liable, but the bill subjects platforms to state and federal civil liability, as well as state criminal law, in this area. It also creates a federal commission to recommend platform design best practices. “STOP CSAM Act,” a bill that includes provisions that make platforms liable for child abuse material but that would also encourage more content monitoring and moderation by platforms, was previously scheduled for a markup with EARN IT Act and will likely be scheduled for the same markup soon.

Congress should act to curb the scourge of child exploitation online. However, the EARN IT Act creates a process that could harm user security and privacy by disincentivizing the use of privacy-protecting technologies such as encryption, disproportionately putting marginalized communities at risk. This would be destructive and unnecessary, as pointed out by Public Knowledge in its updated Section 230 reform scorecard and more than 60 public interest groups in a letter urging Congress to oppose the bill last year.

The following can be attributed to Greg Guice, Director of Government Affairs at Public Knowledge:

“Over the last year, we have seen major new laws passed in states that put many in the LGBTQ+ community at risk, from drag performers to transgender kids and their parents. We have seen decisions from the Supreme Court and federal district courts along with state legislatures undermining the freedoms women have in their bodily autonomy. All to say, the world has changed substantially since EARN IT Act was last introduced. 

“Encryption and privacy, crucial for us all, are at an even higher premium for these vulnerable communities. While this fact in no way minimizes the horrific material EARN IT seeks to stop, the method of addressing child abuse material under the EARN IT Act simply puts too many at risk – all for a speculative structure that, if past is prologue, will lead to less protection for child abuse victims by driving the purveyors of this disgusting material to places outside the purview of law enforcement. Section 230 already has an exception for criminal acts, including distribution of child abuse material, so this is obviously not the solution.

“If we want to address the harm that is caused by child abuse material, then treat it as it should be treated – as a law enforcement matter.”

You may view our letter to Congress opposing the EARN IT Act for encouraging online censorship and jeopardizing access to encrypted services. You may also view our factsheet, “EARN IT Act Does Not Do Enough To Protect Encryption or Competition,” for more information on our concerns, as well as our principles to ensure that any Section 230 reform still protects free expression online – a test EARN IT Act clearly fails in our updated Section 230 scorecard.

The post Public Knowledge Urges Congress To Oppose Bill Threatening Encryption, User Privacy, and Free Expression Online appeared first on Public Knowledge.

Public Knowledge has the pleasure of inviting you to a multifaceted program focused on training and developing the next generation of tech policy experts and public interest advocates that reflects the diversity of voices and experiences in our society.
Please join us for our monthly Career Breakfast Series. This event is designed for students & recent graduates to learn about tech policy and public interest work, careers, and its community. This month you will have the opportunity of having a great conversation with Kayla Gardner.

Kayla is a Policy Manager at Google LLC & works on developing partnerships and engagements in government affairs. She has a background in wireless infrastructure and broadband policy and is a former Congressional staffer and FCC law clerk. Kayla is also a former Public Knowledge intern and participated in the Google Policy Fellowship program. She is a proud alumna of Howard University School of Law and a former 9-1-1 dispatcher with a passion for public safety. Kayla hails from Nashville but has called the DC area home for 15+ years. 

Join us on Friday, May 5th @ 08:00 A.M. ET at The Gathering Spot in Washington, D.C.

This is a private event. However, if you know someone that would be interested in attending, please email michele@publicknowledge.org

The post Privileged Conversations | May 2023 appeared first on Public Knowledge.

The European Commission has recently launched a public consultation on the future of broadband access, including whether large online platforms should pay broadband providers to upgrade their network capacity. This initiative, also known as the “fair share” or “senders-pay” proposal, is backed by telecommunications companies who claim that they need more revenue to invest in network infrastructure, with platforms like Google and Netflix driving a surge in traffic demand without paying their so-called “fair share.”

If you think you’ve heard these arguments before, you have: Broadband providers are making the same arguments against net neutrality they’ve always made, in the U.S. (and around the world). Not much has changed in their outlook since 2005, when Southwestern Bell Corporation’s CEO Ed Whitacre, who was about to become AT&T’s CEO, said that he wasn’t going to “let” his users use search engines like Google, or voice services like Vonage, without demanding those companies pay up. (He did not frame this as a restriction on user choice, but it’s the same thing.) As this is a famous exchange, I’ll excerpt it here in full. Asked by Businessweek interviewer Roger O. Crockett whether he was concerned about internet upstarts like Google, MSN, Vonage, and others, he responded:

“How do you think they’re going to get to customers? Through a broadband pipe. Cable companies have them. We have them. Now what they would like to do is use my pipes free, but I ain’t going to let them do that because we have spent this capital and we have to have a return on it. So there’s going to have to be some mechanism for these people who use these pipes to pay for the portion they’re using. Why should they be allowed to use my pipes? The internet can’t be free in that sense, because we and the cable companies have made an investment and for a Google or Yahoo! or Vonage or anybody to expect to use these pipes [for] free is nuts!”

Many tech companies make a lot of money on the internet, and this has been a “long-standing grievance” of telecommunications companies. They tend to think it is somehow unfair that they sell a product (broadband access) with a guaranteed market, often facing no local competition, that is universally demanded and increasingly used for all forms of commerce, communication, education, and entertainment. We should all have such burdens to bear.

Whether they are worried about “upstarts” in 2005 or dominant tech giants in 2023, the refrain from internet service providers is the same: “Customers should pay us to access the internet — and internet companies should pay us to reach our customers.” This might be framed as a Whitacre-style cash grab, or it might involve a lot of fretting about necessary “investments.” It might be about paying for a “fast lane” (which is the same thing as paying to avoid being throttled) or making companies like Netflix defray their normal operating costs. But, again: It’s the same thing.

We’ve already seen a bill introduced in the U.S. called the “FAIR Contributions Act” that directs the FCC to look for ways to force other companies to pay for an ISP’s network upgrades. Net neutrality opponent and FCC Commissioner Brandan Carr, echoing the views of ISPs, supports the bill, saying that “Big Tech has been enjoying a free ride on our Internet infrastructure.” That’s a clue that this isn’t about incremental reforms to programs like the Connect America Fund, but a wholesale repudiation of net neutrality.

It’s been a minute, so policymakers might need a net neutrality refresher. Net neutrality is the principle that internet service providers should treat all online content equally and not block, slow, or charge extra fees for certain websites or services. This has nothing to do with “content moderation”: ISPs, unlike social media platforms, should be treated as common carriers, due to their unique place in the network and the unilateral power they have to control what their users can access.

Net neutrality remains important whether it’s 2005, 2023, or 2053. Net neutrality preserves free speech by prohibiting ISPs from preventing users from accessing the websites and services of their choice. Even with the rise of platform giants, ISPs are still gatekeepers to the entire internet. Without net neutrality, broadband providers could favor websites that they own or have partnerships with, and suppress those that challenge their opinions or compete with their businesses. Imagine if Comcast or Verizon was run the way Elon Musk runs Twitter.

Net neutrality protects consumers by preventing ISPs from speeding, slowing, or charging higher fees (or fees at all) to certain edge providers. Without net neutrality, ISPs could create fast lanes and slow lanes for different websites or services, charge edge providers to reach users (who would ultimately pay higher prices), or directly charge consumers more money to access certain content. Violating open internet principles in this way would harm internet users who may not be able to afford to access the content they want or need. 

Net neutrality promotes competition by creating a level playing field for new and small companies that offer online content and services. Without net neutrality, ISPs could favor established, dominant, and wealthier players in the market and limit the entry or growth of new or innovative ones. It would also create an unfair advantage for wealthy or powerful companies that can pay for faster delivery of their content. This would stifle innovation and diversity on the internet, while limiting consumer choice and quality.

Broadband providers like to make arguments about “fairness” that collapse under the lightest scrutiny. Residential broadband is primarily an “eyeball network” — with video and audio streaming, much more data traffic goes into those networks than flows back out. (Though upstream connectivity is very important: Just think of the video calls and meetings that have become common since COVID-19.) This traffic is demanded by the ISP’s customers, and ISPs are in the business of providing internet access to those customers, which means delivering the traffic they request. Why is this complicated? My ISP is Comcast, and a lot more traffic comes into my home than flows back out. Yet, somehow I pay Comcast, instead of Comcast paying me, to defray the cost of my Wi-Fi router, computer, and TV streaming box. 

This has not stopped ISPs over the years from arguing that it’s actually unfair that they have to do the job their customers pay them for. (For the nerdy, arguments about “peering” and traffic balance are not applicable to last-mile access networks.) In advocating for “fair share,” European telecommunications CEOs recently wrote that, “As things stand, network operators are in no position to negotiate fair terms with these giant platforms due to their strong market positions, asymmetric bargaining power and the lack of a level regulatory playing field[.]” But there should be little to negotiate to begin with (apart from relatively small issues such as which party pays costs at the interconnection site). Most of the things that ISPs want from content companies should be prohibited by law.

Neither is it true that internet content companies are somehow “free-riding” on the internet. Internet companies invest billions in content delivery networks, global transit networks, data centers, and more. They do all this to deliver content to last-mile ISPs: That’s their job. It’s then the ISPs’ job to get that traffic to users. It is true that internet content companies do not typically pay to hook up new homes or deal with the local permitting issues and expenses involved with operating a residential broadband network. Neither do they pay for snacks in the ISPs’ break rooms. It takes a very expansive view of “free-riding” to encompass others not paying for your expenses. I wish Trader Joe’s would stop free-riding and refusing to pay for my groceries. After all, I’m the one who has to go through all the trouble of getting them home, putting them away, cooking meals, and eating. Unfair!

The network upgrades that ISPs make do not just benefit Big Tech companies, either. Almost every internet service and most users would benefit from a faster, more reliable network with more capacity. Singling out a handful of large, American tech giants, some of which are under rightful antitrust scrutiny, might make political sense, but it’s an odd way to handle network management and upgrade issues.

“Fair share” is not about fairness or connecting the unconnected. It’s about lining the well-lined pockets of broadband providers and their investors. It’s a more limited proposal than one that would allow ISPs to arbitrarily block or throttle any content they wish, but it’s likely only the beginning. Policymakers in the United States should be aware that when incumbent telecommunications operators start complaining about “fairness,” the public stands to lose out.

The post The EU’s “Fair Share” Proposal Is a Threat to Net Neutrality Everywhere appeared first on Public Knowledge.

Earlier this year, Public Knowledge published Back to the Spectrum Future: The 20th Anniversary of the Spectrum Policy Task Force, a white paper that proposes a backcasting model rooted in core public interest principles to help guide our spectrum policymakers toward a wireless future that serves and includes all Americans. A value-based spectrum policy framework allows us to envision a future where everyone has access to reliable and affordable telecommunications services—and then provides a path toward it. Join us for a conversation about the implications of this new approach to spectrum policy in light of NTIA’s current initiative to develop a National Spectrum Strategy. 

Event Timeline

3 pm: Welcome Remarks

3:10-3:40 pm: Fireside Chat with Alan Davidson & Chris Lewis

3:45-4 pm: Paper Presentation by Kathleen Burke

4-4:45 pm: Reaction Panel

Moderated by Harold Feld – Senior Vice President at Public Knowledge

Panelists:

Nicol Turner-Lee – Director at The Center for Technology Innovation (CTI)

Alisa Valentin – Senior Director of Technology & Telecommunication Policy at the National Urban League

Additional Panelists to be added

4:45-6 pm: Happy Hour Reception

The post Back to the Spectrum Future Part II appeared first on Public Knowledge.

Today, the 9th Circuit Court of Appeals ruled in Apple’s favor in the ongoing Epic v. Apple litigation over Apple’s App Store rules that force developers like Epic to pay Apple up to 30% of the revenue they earn from digital transactions in apps. Its litigation against Google is ongoing.

The following quote can be attributed to John Bergmayer, Legal Director at Public Knowledge.

“Epic has been fighting long and hard to empower users and software developers in a mobile app environment dominated by two gatekeepers, Apple and Google. While its court cases are ongoing, this loss shows how current antitrust law, and how courts apply it, is not always fit for the challenges posed by dominant digital platforms.

“That’s why legislation like the Open App Markets Act is necessary to protect users, and the developers who make platforms valuable to users to begin with.”

You may view the decision here.

The post Public Knowledge Responds to Ninth Circuit of Appeals Epic v. Apple Decision appeared first on Public Knowledge.

Today, the Federal Communications Commission voted to approve a Policy Statement to promote a balanced and comprehensive approach to spectrum management. Before this step, any new wireless service had the burden to prove it will not cause any harmful interference to existing services in any potential situation, no matter how unlikely the situation or how poorly designed the existing service. As a result, wireless systems built to work decades ago on outdated assumptions make it increasingly difficult to expand and intensify wireless use in the way we need to meet our ever-growing demand for better mobile services and better Wi-Fi.

The Policy Statement recognizes that ensuring that both new service providers and spectrum incumbents can operate in our increasingly complex radiofrequency environment requires all aspects of our telecommunications system to share the responsibility of mitigating interference. New entrants must still show that they will not cause harmful interference, but existing services must expect that old receivers designed for a quieter world may need to be upgraded to modern standards. Additionally, objections must be based on real-world conditions rather than ideal laboratory performance or unlikely worst case scenarios. This will dramatically speed up the process of approving new wireless uses, and effectively make more spectrum available for everyone.

Public Knowledge applauds the Commission for this important effort to promote a more balanced approach to managing our nation’s spectrum resources.

The following can be attributed to Kathleen Burke, Policy Counsel at Public Knowledge:

“Today, legacy systems too often prevent innovation because they rely on outdated assumptions and have not been upgraded to reflect the current environment, limiting our ability to make full use of our spectrum resources. For far too long, our approach to new technology has focused solely on the new systems without any thought to how incumbent systems can make more room on our spectrum airwaves.

“Upgrading outdated systems and equipment to increase spectrum access is one of the most overlooked aspects of spectrum management – presenting a prime opportunity for re-evaluating our policies in light of technological advancements. This new policy statement embraces a fair approach to managing our spectrum resources by finally adopting the principles that minimizing harmful interference is a mutual obligation of band entrants and incumbents and that no spectrum user has a guarantee of zero interference.”

The post Public Knowledge Commends FCC Action To Promote New Wireless Technologies appeared first on Public Knowledge.

Yesterday, Public Knowledge filed comments on the Federal Trade Commission’s Notice of Proposed Rulemaking on noncompete clauses. Noncompete clauses block employees from working for a competing employer – or starting a competing business after their employment ends. The FTC is considering a proposed rule that would prohibit the use of noncompete clauses as an “unfair method of competition” under Section 5 of the FTC Act.

Noncompete clauses restrict workers, slow innovation, and increase prices for consumers. Public Knowledge argues in its comments that the FTC must use its competition rulemaking authority in order to fulfill Congress’ mandate to stop unfair methods of competition. The agency’s rulemaking authority can help it keep up with changes in the marketplace or in economic learning, use limited resources more efficiently, and provide greater clarity to market participants. Public Knowledge encourages the agency to move swiftly through this process.

The following can be attributed to Charlotte Slaiman, Competition Policy Director at Public Knowledge:

“I’m glad that the FTC is addressing the pernicious problem of noncompete agreements, and it’s even more important that they are using the tool of competition rulemaking to do so. Rules like the proposed rule against noncompete agreements will be a crucial part of the agency’s effort to do more with less: achieving more good for the country with fewer resources. Rules provide people and businesses with needed clarity about what conduct is allowed and prohibited, and simplify enforcement so we waste fewer resources on complex litigations. 

“It’s wonderful to see so much interest and excitement from people across the country in the work of the FTC. This process also reflects an impressive effort by the FTC to bring people into the political process and seek input from a broader range of stakeholders.”

You may view the comments for more information.

The post <strong>Public Knowledge Applauds FTC Rulemaking Effort To Curb Worker Noncompetes</strong> appeared first on Public Knowledge.

Public Knowledge is proud to announce a new member has joined its Board of Directors. Brian Vo will join nine other board members to provide Public Knowledge with strategic counsel and leadership.

Brian Vo, Chief Investment Officer at Connect Humanity, leads the organization’s investment efforts to structure the right type of financing solution that meets the needs of organizations advancing digital equity. He previously served as the Vice President of Social Investment and Innovative Finance at Pact, Inc., a global development NGO. Prior to Pact, Mr. Vo was a director at Quantified Ventures, where he designed outcomes-based transactions for nonprofit and for-profit social enterprises. With McKinsey & Company’s Strategy/Corporate Finance and Public/Social Sector Practices, Mr. Vo advised clients on a range of topics including economic development, growth strategies, capital allocation, operational turnarounds, and transaction structuring.

The following can be attributed to Virginia Lam Abrams, Chair of the Public Knowledge Board of Directors and Executive Vice President at Starry:

“We’re thrilled to welcome Brian Vo as our newest Public Knowledge Board member. Brian’s deep expertise in finance and mission-driven investing will further strengthen our Board capabilities as we continue to support the long-term growth and success of the organization. Today, the Public Knowledge Board is comprised of outstanding individuals that represent a wide array of professional experiences across technology, government, and business. I’m proud of the strength and diversity of our Board and look forward to Brian’s contributions in the coming years.”

The following can be attributed to Chris Lewis, President and CEO of Public Knowledge:

“I am excited that our Board of Directors has chosen to add Brian to the Board and that he has chosen to serve the public interest in this way. Brian brings unique skills and perspectives to our Board with his experience in growing investment in social action. He also has a dedication to issues at the center of our work, especially on closing the digital divide. Brian joins a dedicated team of Directors who continue to steward Public Knowledge’s growth as a leader in tech policy and the public interest – and I continue to be grateful for their commitment and leadership.”

You may view our team page for more information on all members of our Board of Directors.

The post Public Knowledge Welcomes New Member to Board of Directors appeared first on Public Knowledge.

Today, Public Knowledge and New America’s Open Technology Institute, on behalf of the Public Interest Spectrum Coalition, filed comments with the National Telecommunications and Information Administration in response to the agency’s Request for Comment on developing a national spectrum strategy. The filing urges the NTIA to adopt a national spectrum strategy that will not only secure our nation’s future as a wireless leader but also serve the public by moving us towards a future that serves and includes all Americans.

Creating a wireless future we can all enjoy requires guiding policies that are rooted in the public interest, rather than narrowly focusing on a specific industry or technology like 6G or Wi-Fi.The filing follows the launch of Public Knowledge’s recent white paper, “Back to the Spectrum Future: The 20th Anniversary of the Spectrum Policy Task Force,” by Public Knowledge Policy Counsel Kathleen Burke, advocating for adopting a backcasting model rooted in core public interest principles to help guide our spectrum policymakers toward a wireless future that serves and includes all Americans.

The following can be attributed to Kathleen Burke, Policy Counsel at Public Knowledge:

“Despite advances in technology that have turned junk bands into prime spectrum, spectrum greenfields have dwindled to near extinction. Meanwhile, our nation’s ad hoc approach to freeing up our underutilized airwaves has not once managed to fully satiate technology’s appetite for spectrum. Why? Because while technology changes, values endure. It is time for a new approach centered on what we want to achieve – providing affordable universal access, encouraging innovation, while preserving national defense – rather than on giving this band to mobile carriers or that band to the Defense Department. 

“With advances in radio technologies such as dynamic spectrum sharing, sensing technology, automatic frequency coordination databases, Multiple-Input Multiple-Output (MIMO) systems, and tools like advanced AI management models on the horizon, we now have the opportunity and an obligation to fundamentally rethink how we manage the public airwaves. This shift in thinking is essential if we hope to achieve our nation’s telecommunications goals – including finally providing access to affordable and reliable telecommunications services for all Americans.”

You may view the comments here. You may also view our blog post, “Back to the Spectrum Future: How a Public Interest Framework Can Create a Wireless Future that Benefits Us All,” for more information on how a values-based spectrum policy framework can benefit everyone.

The post Public Knowledge Files Comments Urging NTIA To Adopt a National Spectrum Strategy Based on Public Interest Values appeared first on Public Knowledge.