Comments to the FCC on the Two Under-Developed Issues in the Open Internet Proceeding

November 2, 2010

ITIF has filed reply comments with the FCC in the “Two Questions Inquiry” on managed services and wireless net neutrality. This reply addresses criticism of our previous comments by Skype. Skype argued that our assertion that their video conferencing service uses a large amount of bandwidth is “unfounded,” but they confuse the requirements of their free person-to-person video calling product with those of their for-fee group video conferencing service. Our reply cites information from Skype’s web site that supports our previous claim.

We also suggest that the confusion between Skype’s historical service and its emerging one illustrates a pitfall of premature regulation. The regulations that the FCC contemplates for managed services and wireless networks must not only accommodate the needs of historical applications such as person-to-person video calling, they must accommodate the needs of new and emerging applications such as high-quality group video conferencing. Many of the comments filed in these dockets have tended to over-emphasize historical applications to the detriment of new and emerging ones, and regulations adopted by the FCC must support ongoing innovation.