You're a lawyer now? :)

For the record, blocking a delivery method != blocking content.

Josh Reynolds
CIO, SPITwSPOTS
www.spitwspots.com

On 06/10/2015 12:02 PM, Ken Hohhof wrote:
You are not allowed to block legal content.  Period.
If you rate limit it, you could perhaps claim it is reasonable network management, but “no throttling” is another of the 3 bright line rules. Remember one of the 2 or 3 actual cases of “bad behavior” cited for justifying all this was Comcast interfering with Bit Torrent back in something like 2007, and they weren’t even outright blocking it. As far as being sued, a customer could file a complaint with the FCC, rather than pursuing civil damages, likely that is the way they would go since all they have to do is fill in a form on the FCC website. My guess is the FCC will be much more interested in pursuing complaints from the likes of Netflix, Cogent and Level3 against the likes of Comcast, Verizon and Time Warner. Unless you piss off John Oliver. So it might just be like the BBB, they just send you the complaint and let you figure out what to do with it. That reminds me, I need to check if we are supposed to be registering a contact to receive Open Internet Order complaints, that kind of rings a bell, but maybe I’m confusing it with having a DC registered agent for CPNI complaints if you file Form 499. The other factor on your side is the customer might not want to complain to the FCC if their reasons for using Bit Torrent are not exactly legal or moral. And customers wanting to torrent legitimate content, like maybe Linux ISOs, will probably just use another method and not have a cow over it.
*From:* Josh Reynolds <mailto:[email protected]>
*Sent:* Wednesday, June 10, 2015 2:46 PM
*To:* [email protected] <mailto:[email protected]>
*Subject:* Re: [AFMUG] EPMP 10 mhz vs 20mhz
I'll say this again: After consulting with no less than 3 legal firms who specialize in communications/fcc law, we are in the clear. I'm not going to get into a debate about the legality of this because (A) I'm not a lawyer and (B) neither are you. We have been told that subscribers agree to the restrictions on our network when they sign a contract. The language is the same used for commercial services.

Yes, the restriction applies to all torrent traffic.
Josh Reynolds
CIO, SPITwSPOTS
www.spitwspots.com
On 06/10/2015 11:37 AM, Josh Luthman wrote:
IMO your only concern should be getting sued. Anyone that's torrenting stuff probably doesn't have the money for a lawyer to do that.
Do you do any CIR connections for businesses?  Do you block them?
Josh Luthman
Office: 937-552-2340
Direct: 937-552-2343
1100 Wayne St
Suite 1337 3
Troy, OH 45373
On Wed, Jun 10, 2015 at 3:35 PM, Josh Reynolds <[email protected] <mailto:[email protected]>> wrote:

    And after that based on the legal advice we have received from no
    less than 3 Communications Lawyers

    Josh Reynolds
    CIO, SPITwSPOTS
    www.spitwspots.com  <http://www.spitwspots.com>

    On 06/10/2015 09:41 AM, Ken Hohhof wrote:
    And you can legally do it until this Friday.
    *From:* Josh Reynolds <mailto:[email protected]>
    *Sent:* Wednesday, June 10, 2015 12:10 PM
    *To:* [email protected] <mailto:[email protected]>
    *Subject:* Re: [AFMUG] EPMP 10 mhz vs 20mhz

    We have been blocking torrents as a network protection measure
    for over 6 years using various DPI and behavioral detection
    systems, and its in our AUP. We have never lost a customer or
    even had a complaint because of it.

    On Jun 10, 2015 4:56 AM, Mathew Howard
    mailto:[email protected] wrote:

        Agreed. I don't even want to think about how many calls we
        would have to deal with if blocked VPNs... and torrents for
        that matter.
        On Wed, Jun 10, 2015 at 7:10 AM, Mike Hammett
        <[email protected] <mailto:[email protected]>> wrote:

            Yes and blindly killing things is a terrible practice.



            -----
            Mike Hammett
            Intelligent Computing Solutions
            http://www.ics-il.com

            
<https://www.facebook.com/ICSIL><https://plus.google.com/+IntelligentComputingSolutionsDeKalb><https://www.linkedin.com/company/intelligent-computing-solutions><https://twitter.com/ICSIL>

            Midwest Internet Exchange
            http://www.midwest-ix.com

            
<https://www.facebook.com/mdwestix><https://www.linkedin.com/company/midwest-internet-exchange><https://twitter.com/mdwestix>
            
------------------------------------------------------------------------
            *From: *"Paul McCall" <[email protected]
            <mailto:[email protected]>>
            *To: *[email protected] <mailto:[email protected]>
            *Sent: *Tuesday, June 9, 2015 11:12:43 PM

            *Subject: *Re: [AFMUG] EPMP 10 mhz vs 20mhz

            Rory, how do you “kill torrents”? technically,

            And, aren’t there a lot o legitimate programs that use
            torrents as the distribution method?

            *From:*Af [mailto:[email protected]
            <mailto:[email protected]>] *On Behalf Of *Rory Conaway
            *Sent:* Monday, June 08, 2015 3:54 PM
            *To:* [email protected] <mailto:[email protected]>
            *Subject:* Re: [AFMUG] EPMP 10 mhz vs 20mhz

            If you have file sharers on there for example, I’ve seen
            XM radios drop to 10Mbps or less (another reason we kill
            torrents).  If you watch the modulation levels when that
            happens, you will also see them drop as the CPU load
            goes up.

            Rory

            *From:*Af [mailto:[email protected]
            <mailto:[email protected]>] *On Behalf Of *Josh Luthman
            *Sent:* Monday, June 08, 2015 12:46 PM
            *To:* [email protected] <mailto:[email protected]>
            *Subject:* Re: [AFMUG] EPMP 10 mhz vs 20mhz

            PS in the run queue? That certainly isn't load, there's
            no way an XM radio can do 20+.

            Josh Luthman
            Office: 937-552-2340 <tel:937-552-2340>
            Direct: 937-552-2343 <tel:937-552-2343>
            1100 Wayne St
            Suite 1337
            Troy, OH 45373

            On Mon, Jun 8, 2015 at 3:41 PM, Bill Prince
            <[email protected] <mailto:[email protected]>> wrote:

            I'm with Rory. It depends a lot on the traffic, and and
            what role it may be playing (backhaul, AP, or SM). This
            is just a 1 day snapshot of one in SM role.



            bp

            <part15sbs{at}gmail{dot}com>

            On 6/8/2015 12:34 PM, Josh Luthman wrote:

                SSH into every single AP and it says 0.00 or 0.01. I
                used to graph it way back (maybe 5.3 days?) and I
                never saw it deviate.  This is definitely all XM gear.

                Josh Luthman
                Office: 937-552-2340 <tel:937-552-2340>
                Direct: 937-552-2343 <tel:937-552-2343>
                1100 Wayne St
                Suite 1337
                Troy, OH 45373

                On Mon, Jun 8, 2015 at 3:27 PM, Rory Conaway
                <[email protected]
                <mailto:[email protected]>> wrote:

                I would have to se your data, mine does not support
                that.

                Sent from fromm phone where I type with a single
                digit so please excuse shortcuts or typos.

                Rory Conaway

                Triad Wireless



                -------- Original message --------
                From: Josh Luthman <[email protected]
                <mailto:[email protected]>>
                Date: 06/08/2015 3:26 PM (GMT-05:00)
                To: [email protected] <mailto:[email protected]>
                Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz

                If that was the case why are the loads of every
                radio 0.01 or less?

                Josh Luthman
                Office: 937-552-2340 <tel:937-552-2340>
                Direct: 937-552-2343 <tel:937-552-2343>
                1100 Wayne St
                Suite 1337
                Troy, OH 45373

                On Mon, Jun 8, 2015 at 3:22 PM, Rory Conaway
                <[email protected]
                <mailto:[email protected]>> wrote:

                    To prove my point further, if you do throughput
                    testing with Ubiquity in ptmp mode, you will
                    find with xm radios, cpu load affects modulation
                    levels.  I haven't tested xw radios yet but I
                    believe the threshold is just higher and
                    probably justifies 30mhz but it's going to be close.

                    Sent from fromm phone where I type with a single
                    digit so please excuse shortcuts or typos.

                    Rory Conaway

                    Triad Wireless



                    -------- Original message --------

                    From: Rory Conaway <[email protected]
                    <mailto:[email protected]>>
                    Date: 06/08/2015 3:16 PM (GMT-05:00)
                    To: [email protected] <mailto:[email protected]>
                    Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz

                    The pps and cpu load absolutely is another
                    variable you need to take into acount,
                    especially with 400 and 526mhz atheros
                    processors that are also running polling. Ignore
                    it as part of your overall strategy and you
                    could be wasting spectrum.  If your ap never
                    exceeds 80mbps, why do you want 30mhz channels.
                    Sarcasm aside, does that help you understand my
                    point.

                    Sent from fromm phone where I type with a single
                    digit so please excuse shortcuts or typos.

                    Rory Conaway

                    Triad Wireless



                    -------- Original message --------
                    From: Josh Reynolds <[email protected]
                    <mailto:[email protected]>>
                    Date: 06/08/2015 2:17 PM (GMT-05:00)
                    To: [email protected] <mailto:[email protected]>
                    Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz

                    I think we are having two different
                    conversations, and I have no idea what you are
                    talking about right now.

                    What we were discussing has to do with channel
                    sizes, epmp, and ubiquiti. In particular, why
                    UBNT 40mhz isn't any better than 30mhz in terms
                    of efficiency.

                    This part of the discussion has nothing at all
                    to do with any theories on PPS you may have,
                    other than those you have tried to inject into
                    this discussion.

                    On Jun 8, 2015 10:07 AM, Rory Conaway
                    <[email protected]
                    <mailto:[email protected]>> wrote:

                    Excopt that as was mentioned before, the s/n
                    ratio goes down and if you aren't hitting the
                    limits of the physical layer in 20MHz, why do it?

                    Sent from fromm phone where I type with a single
                    digit so please excuse shortcuts or typos.

                    Rory Conaway

                    Triad Wireless



                    -------- Original message --------
                    From: Josh Reynolds <[email protected]
                    <mailto:[email protected]>>
                    Date: 06/08/2015 12:43 PM (GMT-05:00)
                    To: [email protected] <mailto:[email protected]>
                    Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz

                    I can assure you that on radios connected in a
                    ptp config or small ptmp, that you will see more
                    throughput on the 30mhz channel given a noise
                    floor of -97 and signals in the mid -50s, even
                    with nothing connected on the other side of the
                    radios.

                    Its an efficiency issue.

                    On Jun 8, 2015 8:13 AM, Mathew Howard
                    <[email protected]
                    <mailto:[email protected]>> wrote:

                    I kind of does, the way I understood it, that
                    bottleneck limited you from really being able to
                    do anything beyond what a 30mhz channel could
                    support.

                    Now that I think about it, I have seen 40mhz
                    perform better than 30mhz... but yes, that was
                    because of RF problems, and neither one was
                    doing anything close to what it would with a
                    good link.

                    On Mon, Jun 8, 2015 at 11:09 AM, Josh Reynolds
                    <[email protected]
                    <mailto:[email protected]>> wrote:

                    That is a bottleneck in the system, but not
                    relevant as far as this discussion goes. That
                    has nothing to do with the 30/40MHz channel
                    efficiency per say.

                    On Jun 8, 2015 8:03 AM, Rory Conaway
                    <[email protected]
                    <mailto:[email protected]>> wrote:

The limitation on the older xm radios was pps. When you added a lot of small packets and
                    airmax, you could drop down to as low as
                    40Mbps.  In the real world in ptmp mode. We
                    planned for 50mhz per AP with eveything g taken
                    into account.

                    Sent from fromm phone where I type with a single
                    digit so please excuse shortcuts or typos.

                    Rory Conaway

                    Triad Wireless



                    -------- Original message --------
                    From: Josh Reynolds <[email protected]
                    <mailto:[email protected]>>
                    Date: 06/08/2015 11:59 AM (GMT-05:00)
                    To: [email protected] <mailto:[email protected]>
                    Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz

                    This. Thought it was pretty obvious but I guess
                    I assumed too much out of some on this list ;)

                    On Jun 8, 2015 7:33 AM, Jeremy
                    <[email protected]
                    <mailto:[email protected]>> wrote:

                    I think he is talking about using 40MHz channels
                    on the older M series, that didn't have gig
                    ports.  It was my understanding that the
                    processor would get taxed as well on a 40MHz
                    channel, making 30MHz actually work better.

                    On Mon, Jun 8, 2015 at 9:24 AM, Josh Luthman
                    <[email protected]
                    <mailto:[email protected]>> wrote:

                    Ubnt and epmp have gig ports.

                    Josh Luthman
                    Office: 937-552-2340 <tel:937-552-2340>
                    Direct: 937-552-2343 <tel:937-552-2343>
                    1100 Wayne St
                    Suite 1337
                    Troy, OH 45373

                    On Jun 8, 2015 11:20 AM, "Josh Reynolds"
                    <[email protected]
                    <mailto:[email protected]>> wrote:

                    I don't know how epmp does it.

                    For UBNT, a 30mhz channel is just a "fat" 20mhz
                    channel in the atheros chip. Single operation.
                    For  a 40mhz channel, it's really two 20s,
                    meaning radio operations are ran twice. Loss in
                    efficiency, also marred by the lack of gigabit port.

                    On Jun 8, 2015 7:13 AM, Mathew Howard
                    <[email protected]
                    <mailto:[email protected]>> wrote:

                    I've never seeing much difference in performance
                    on the ubnt M series between 30mhz and 40mhz
                    channels, so yes, I would say that is true...
                    but I'm not sure how much applies to ePMP - they
                    do have a much a faster processor and on a
                    software level they are very different.

                    So far, I have been running all of our ePMP APs
                    on 20mhz channels and PTP links on 40mhz or
                    20mhz, depending on how much capacity they need.
                    I haven't really seen much need to go down to
                    10mhz channels with ePMP.

                    On Mon, Jun 8, 2015 at 8:43 AM, Shayne Lebrun
                    <[email protected]
                    <mailto:[email protected]>> wrote:

                    I seem to recall that with the M series, at
                    least, a 30 mhz channel works 'better' than a 40
                    because the 40 is really two 20 mhz channels
                    bonded together, where a 30 mhz channel is a 30
                    mhz channel.

                    -----Original Message-----
                    From: Af [mailto:[email protected]
                    <mailto:[email protected]>] On Behalf Of Rory
                    Conaway
                    Sent: Saturday, June 6, 2015 8:32 PM
                    To: [email protected] <mailto:[email protected]>
                    Subject: Re: [AFMUG] EPMP 10 mhz vs 20mhz

                    I'm not that familiar with the ePMP's yet but I
                    can tell you some things that we saw with
                    Ubiquiti.  One is that channel width does not
scale with bandwidth that that Atheros chipset. For example, 40MHz channels rarely hit their
                    theoretical maximum due to a variety of factors,
                    noise, lower s/n, processor limitations, etc...
                    Second, 20MHz channels seem to be the sweet spot
                    but even with GPS sync, you have to deal with
                    reflections. Third, 10MHz channels have more
                    overhead as a percentage of total capacity and
                    don't handle a lot of users well (above 40 for
                    example with the older 400MHz chipsets. I'm
                    starting to deploy XW radios with the 520MHz
                    processors but everything is 20MHz now so I
                    don't have a comparison). We did see peaks of
                    32Mbps with some customers on 10MHz channels but
                    that's non-peak times.  In peak times, we were
                    seeing 8Mbps when more users were online.

                    Rory


                    -----Original Message-----
                    From: Af [mailto:[email protected]
                    <mailto:[email protected]>] On Behalf Of
                    Craig House
                    Sent: Saturday, June 06, 2015 5:20 PM
                    To: [email protected] <mailto:[email protected]>

                    Subject: [AFMUG] EPMP 10 mhz vs 20mhz

                    We have deployed 6 towers to begin our new EPMP
                    network and 4 of those towers have a full
                    cluster of 2.4 90 degree EPMP sectors.  They are
                    configured with ACS turned off now because in
                    several cases they all ended up on the same or
                    very close to the same channel.  I have Front
                    back designations and non overlapping channels
                    set up on all towers.  I have tried 40 mhz 20
                    mhz and now 10mhz channels and while the
                    customer stability has gotten better the more I
                    play with settings I have kind of hit a point I
                    dont know what else to try. I have some that the
                    uplink quality will vary wildly from 100% to 0%.
                    Most have gotten better since I went to a 10mhz
                    channel.  Most of the customers get 12MB -30mb
                    down in the wireless link test but the uplinks
                    are as bad as .17. What is the cause of this
                    poor uplink quality?  Is it interfernece? My one
                    5ghz AP does not have this problem but even with
                    noise many of these customers have -50 signals
                    and oddly enough the ones with the great signals
                    seem to be the ones that have the poorest link
                    tests on the up link side.  I also have customes
                    with -65 or -72 signals that get 5MB up on the
                    same sectors?  Im scratching my head a bit on
                    what the fix is for this? Should I leave ACS on
                    and change everything to 10mhz channels? Will a
                    full cluster with ACS on work all on the same
                    channel?
                    I'm used to FSK where you pick your channel and
                    any channels that are adjacent will cause
                    problems with connected SM's.  So am I just
                    applying old knowledge to a technology that it
                    doesn't apply to?

                    Craig




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