Lots of good stuff here and I missed the earlier posts, but one small
thing caught my attention:
> About 10 years ago, I accidentally got involved in a patent
dispute to be an "expert witness", for a patent involving
downloading new programs over a communications path into a remote
computer (yes, what all our devices do almost every day).
In the seminal period of late 1968 and early 1969 when we were
thinking about Arpanet protocols, one idea that was very much part of
our thinking was downloading a small program at the beginning of an
interactive session. The downloaded program would take care of local
interactions to avoid the need to send every character across the net
only to have it echoed remotely. Why not always use local echo?
Because most of the time-shared systems in the various ARPA-supported
research environments had distinct ways of interpreting each and
every character. Imposing a network-wide rule of local echoing would
have compromised the usability of most of the systems on the Arpanet.
I think Multics was the only "modern" line-at-a-time system at the time.
In March 1969 we decided it was time to write down the ideas from our
meetings in late 1968 and early 1969. The first batch of RFCs
included Rulifson's RFC 5. He proposed DEL, the Decode-Encode
Language. Elie's RFC 51 a year later proposed the Network Interchange
Language. In both cases the basic concept was the creation of a
simple language, easily implementable on each platform, that would
mediate the interaction with a remote system. The programs were
expected to be short -- hence downloadable quickly -- and either
interpreted or quickly translated. There was a tiny bit of
experimental work along this line, but it was far ahead of its time.
I think it was about 25 years before ActiveX came along, followed by Java.
Steve
On Tue, Oct 10, 2023 at 11:30 AM Dave Taht via Nnagain
<[email protected]> wrote:
On Mon, Oct 9, 2023 at 7:56 PM Jack Haverty via Nnagain
<[email protected]> wrote:
For starters it is an honor to be conversing with folk that knew Bob
Taylor, and "Lick", and y'all made me go back and re-read
http://memex.org/licklider.pdf
For inspiration. I think everyone in our field should re-read that,
periodically. For example he makes an overgeneralization about the
thinking processes of men, as compared to the computers of the time,
and not to women...
But I have always had an odd question - what songs did Lick play on
guitar? Do any recordings exist?
Music defines who I am, at least. I love the angularness and surprises
in jazz, and the deep storytelling buried deep in Shostakovich's
Fifth. Moving forward to modern music: the steady backbeat of Burning
Man - and endless repetition of short phrases - seems to lead to
groupthink - I can hardly stand EDM for an hour.
I am "maked" by Angela' Lansbury's Sweeny Todd, and my religion,
forever reformed by Monty Python's Life of Brian, One Flew over the
Cookoos nest, 12 Angry Men, and the 12 Monkees, Pink Floyd and punk
music were the things that shaped me. No doubt it differs
significantly for everyone here, please share?
Powerful tales and their technologies predate the internet, and
because they were wildly shared, influenced how generations thought
without being the one true answer. Broadcast media, also, was joint,
and in school we
We are in a new era of uncommonality of experience, in part from
bringing in all the information in the world, while still separated by
differences in language, exposure, education, and culture, although
nowadays it has become so easy and natural to be able to use computer
assisted language translation tools, I do not know how well they truly
make the jump between cultures.
In that paper he talked about 75% of his time being spent setting up
to do analytics, where today so much information exists as to be
impossible to analyze.
I only have a few more small comments below, but I wanted to pick out
the concepts of TOS and backpressure as needing thought on another
day, in another email (what was licks song list??? :)). The internet
has very little Tos or backpressure, and Flow Queuing based algorithms
actually function thusly:
If the arrival rate of a flow is less than the departure rate of all
other flows, it goes out first.
To some extent this matches some of Nagles' "every application has a
right to one packet in the network", and puts a reward into the system
for applications that use slightly less than their fair share of the
bandwidth.
> IMHO, the problem may be that the Internet, and computing
technology in general, is so new that non-technical organizations,
such as government entities, don't understand it and therefore
can't figure out whether or how to regulate anything involved.
>
> In other, older, "technologies", rules, procedures, and
traditions have developed over the years to provide for feedback
and control between governees and governors. Roberts Rules of
Order was created 150 years ago, and is still widely used to
manage public meetings. I've been in local meetings where
everyone gets a chance to speak, but are limited to a few minutes
to say whatever's on their mind. You have to appear in person,
wait your turn, and make your comment. Doing so is free, but still
has the cost of time and hassle to get to the meeting.
>
> Organizations have figured out over the years how to manage
meetings. [Vint - remember the "Rathole!" mechanism that we used
to keep Internet meetings on track...?]
PARC had "Dealer".
> From what David describes, it sounds like the current "public
comment" mechanisms in the electronic arena are only at the stage
where the loudest voices can drown out all others, and public
debates are essentially useless cacophonies of the loudest
proponents of the various viewpoints. There are no rules. Why
should anyone submit their own sensible comments, knowing they'll
be lost in the noise?
>
> In non-electronic public forums, such behavior is ruled out, and
if it persists, the governing body can have offenders ejected,
adjourn a meeting until cooler heads prevail, or otherwise make
the discourse useful for informing decisions. Courts can issue
restraining orders, but has any court ever issued such an order
applying to an electronic forum?
>
> So, why haven't organizations yet developed rules and mechanisms
for managing electronic discussions....?
>
> I'd offer two observations and suggestions.
>
> -----
>
> First, a major reason for a lack of such rules and mechanisms
may be an educational gap. Administrators, politicians, and
staffers may simply not understand all this newfangled technology,
or how it works, and are drowning in a sea of terminology,
acronyms, and concepts that make no sense (to them). In the FCC
case, even the technical gurus may have deep knowledge of their
traditional realm of telephony, radio, and related issues and
policy tradeoffs. But they may be largely ignorant of computing
and networking equivalents. Probably even worse, they may
unconsciously consider the new world as a simple evolution of the
old, not recognizing the impact of incredibly fast computers and
communications, and the advances that they enable, such as "AI" -
whatever that is...
>
> About 10 years ago, I accidentally got involved in a patent
dispute to be an "expert witness", for a patent involving
downloading new programs over a communications path into a remote
computer (yes, what all our devices do almost every day). I was
astounded when I learned how little the "judicial system"
(lawyers, judges, legislators, etc.) knew about computer and
network technology. That didn't stop them from debating the
meaning of technical terms. What is RAM? How does "programming"
differ from "reprogramming"? What is "memory"? What is a
"processor"? What is an "operating system"? The arguments
continue until eventually a judge declares what the answer is,
with little technical knowledge or expertise to help. So you can
easily get legally binding definitions such as "operating system"
means "Windows", and that all computers contain an operating system.
>
> I spent hours on the phone over about 18 months, explaining to
the lawyers how computers and networks actually worked. In turn,
they taught me quite a lot about the vagaries of the laws and
patents. It was fascinating but also disturbing to see how
ill-prepared the legal system was for new technologies.
>
> So, my suggestion is that a focus be placed on helping the
non-technical decision makers understand the nuances of computing
and the Internet. I don't think that will be successful by
burying them in the sea of technical jargon and acronyms.
>
> Before I retired, I spent a lot of time with C-suite denizens
from companies outside of the technology industry - banks,
manufacturers, transportation, etc. - helping them understand what
"The Internet" was, and help them see it as both a huge
opportunity and a huge threat to their businesses. One technique
I used was simply stolen from the early days of The Internet.
>
> When we were involved in designing the internal mechanisms of
the Internet, in particular TCPV4, we didn't know much about
networks either. So we used analogies. In particular we used the
existing transportation infrastructure as a model. Moving bits
around the world isn't all that different from moving goods and
people. But everyone, even with no technical expertise, knows
about transportation.
>
> It turns out that there are a lot of useful analogies. For
example, we recognized that there were different kinds of
"traffic" with different needs. Coal for power plants was
important, but not urgent. If a coal train waits on a siding
while a passenger train passes, it's OK, even preferred. There
could be different "types of service" available from the
transportation infrastructure. At the time (late 1970s) we
didn't know exactly how to do that, but decided to put a field in
the IP header as a placeholder - the "TOS" field. Figuring out
what different TOSes there should be, and how they would be
handled differently, was still on the to-do list. There are even
analogies to the Internet - goods might travel over a "marine
network" to a "port", where they are moved onto a "rail network",
to a distributor, and moved on the highway network to their final
destination. Routers, gateways, ...
>
> Other transportation analogies reinforced the notion of TOS.
E.g., if you're sending a document somewhere, you can choose how
to send it - normal postal mail, or Priority Mail, or even use a
different "network" such as an overnight delivery service.
Different TOS would engage different behaviors of the underlying
communications system, and might also have different costs to use
them. Sending a ton of coal to get delivered in a week or two
would cost a lot less than sending a ton of documents for
overnight delivery.
>
> There were other transportation analogies heard during the TCPV4
design discussions - e.g., "Expressway Routing" (do you take a
direct route over local streets, or go to the freeway even though
it's longer) and "Multi-Homing" (your manufacturing plant has
access to both a highway and a rail line).
>
> Suggestion -- I suspect that using a familiar infrastructure
such as transport to discuss issues with non-technical decision
makers would be helpful. E.g., imagine what would happen if some
particular "net neutrality" set of rules was placed on the
transportation infrastructure? Would it have a desirable effect?
>
> -----
>
> Second, in addition to anonymity as an important issue in the
electronic world, my experience as a mentee of Licklider surfaced
another important issue in the "galactic network" vision -- "Back
Pressure". The notion is based in existing knowledge.
Economics has notions of Supply and Demand and Cost Curves.
Engineering has the notion of "Negative Feedback" to stabilize
mechanical, electrical, or other systems.
>
> We discussed Back Pressure, in the mid 70s, in the context of
electronic mail, and tried to get the notion of "stamps" accepted
as part of the email mechanisms. The basic idea was that there
had to be some form of "back pressure" to prevent overload by
discouraging sending of huge quantities of mail.
>
> At the time, mail traffic was light, since every message was
typed by hand by some user. In Lick's group we had experimented
with using email as a way for computer programs to interact. In
Lick's vision, humans would interact by using their computers as
their agents. Even then, computers could send email a lot faster
and continuously than any human at a keyboard, and could easily
flood the network. [This epiphany occurred shortly after a
mistake in configuring distribution lists caused so many messages
and replies that our machine crashed as its disk space ran out.]
>
> "Stamps" didn't necessarily represent monetary cost. Back
pressure could be simple constraints, e.g., no user can send more
than 500 (or whatever) messages per day. This notion never got
enough support to become part of the email standards; I still
think it would help with the deluge of spam we all experience today.
>
> Back Pressure in the Internet today is largely non-existent. I
(or my AI and computers) can send as much email as I like.
Communications carriers promote "unlimited data" but won't
guarantee anything. Memory has become cheap, and as a result
behaviors such as "buffer bloat" have appeared.
>
> Suggestion - educate the decision-makers about Back Pressure,
using highway analogies (metering lights, etc.)
>
> -----
>
> Education about the new technology, but by using some familiar
analogs, and introduction of Back Pressure, in some appropriate
form, as part of a "network neutrality" policy, would be the two
foci I'd recommend.
>
> My prior suggestion of "registration" and accepting only the
last comment was based on the observations above. Back pressure
doesn't have to be monetary, and registered users don't have to be
personally identified. Simply making it sufficiently "hard" to
register (using CAPTCHAs, 2FA, whatever) would be a "cost"
discouraging "loud voices". Even the law firms submitting
millions of comments on behalf of their clients might balk at the
cost (in labor not money) to register their million clients, even
anonymously, so each could get his/her comment submitted. Of
course, they could always pass the costs on to their (million?
really?) clients. But it would still be Back Pressure.
>
> One possibility -- make the "cost" of submitting a million
electronic comments equal to the cost of submitting a million
postcards...?
>
> Jack Haverty
>
>
> On 10/9/23 16:55, David Bray, PhD wrote:
>
> Great points Vint as you're absolutely right - there are
multiple modalities here (and in the past it was spam from
thousands of postcards, then mimeographs, then faxes, etc.)
>
> The standard historically has been set by the Administrative
Conference of the United States: https://www.acus.gov/about-acus
>
> In 2020 there seemed to be an effort to gave the General
Services Administration weigh-in, however they closed that
rulemaking attempt without publishing any of the comments they got
and no announcement why it was closed.
>
> As for what part of Congress - I believe ACUS was championed by
both the Senate and House Judiciary Committees as it has oversight
and responsibility for the interpretations of the Administrative
Procedure Act of 1946 (which sets out the whole rulemaking procedure).
>
> Sadly there isn't a standard across agencies - which also means
there isn't a standard across Administrations. Back in 2018 and
2020, both with this group of 52 people here
https://tinyurl.com/letter-signed-52-people - as well as
individually - I did my darnest to encourage them to do a standard.
>
> There's also the National Academy of Public Administration which
is probably the latest remaining non-partisan forum for
discussions like this too.
>
>
> On Mon, Oct 9, 2023 at 7:46 PM Vint Cerf <[email protected]> wrote:
>>
>> David, this is a good list.
>> FACA has rules for public participation, for example.
>>
>> I think it should be taken into account for any public
commenting process that online (and offline such as USPS or fax
and phone calls) that spam and artificial inflation of comments
are possible. Is there any specific standard for US agency public
comment handling? If now, what committees of the US Congress might
have jurisdiction?
>>
>> v
>>
>>
>> On Tue, Oct 10, 2023 at 8:22 AM David Bray, PhD via Nnagain
<[email protected]> wrote:
>>>
>>> I'm all for doing new things to make things better.
>>>
>>> At the same time, I used to do bioterrorism preparedness and
response from 2000-2005 (and aside from asking myself what kind of
crazy world needed counter-bioterrorism efforts... I also realized
you don't want to interject something completely new in the middle
of an unfolding crisis event). If something were to be injected
now, it would have to have consensus from both sides, otherwise at
least one side (potentially detractors from both) will claim that
whatever form the new approaches take are somehow advantaging "the
other side" and disadvantaging them.
>>>
>>> Probably would take a ruling by the Administrative Conference
of the United States, at a minimum to answer these five questions
- and even then, introducing something completely different in the
midst of a political melee might just invite mudslinging unless
moderate voices on both sides can reach some consensus.
>>>
>>> 1. Does identity matter regarding who files a comment or not —
and must one be a U.S. person in order to file?
>>>
>>> 2. Should agencies publish real-time counts of the number of
comments received — or is it better to wait until the end of a
commenting round to make all comments available, including counts?
>>>
>>> 3. Should third-party groups be able to file on behalf of
someone else or not — and do agencies have the right to remove
spam-like comments?
>>>
>>> 4. Should the public commenting process permit multiple
comments per individual for a proceeding — and if so, how many
comments from a single individual are too many? 100? 1000? More?
>>>
>>> 5. Finally, should the U.S. government itself consider, given
public perceptions about potential conflicts of interest for any
agency performing a public commenting process, whether it would be
better to have third-party groups take responsibility for
assembling comments and then filing those comments via a validated
process with the government?
>>>
>>>
>>>
>>> On Sat, Oct 7, 2023 at 4:10 PM Jack Haverty <[email protected]>
wrote:
>>>>
>>>> Hi again David et al,
>>>>
>>>> Interesting frenzy...lots of questions that need answers and
associated policies. I served 6 years as an elected official (in
a small special district in California), so I have some small
understanding of the government side of things and the constraints
involved. Being in charge doesn't mean you can do what you want.
>>>>
>>>> I'm thinking here more near-term and incremental steps. You
said "These same questions need pragmatic pilots that involve the
public ..."
>>>>
>>>> So, how about using the current NN situation for a pilot?
Keep all the current ways and emerging AI techniques to continue
to flood the system with comments. But also offer an *optional*
way for humans to "register" as a commenter and then submit their
(latest only) comment into the melee. Will people use it? Will
"consumers" (the lawyers, commissioners, etc.) find it useful?
>>>>
>>>> I've found it curious, for decades now, that there are (too
many) mechanisms for "secure email", that may help with the flood
of disinformation from anonymous senders, but very very few people
use them. Maybe they don't know how; maybe the available schemes
are too flawed; maybe ...?
>>>>
>>>> About 30 years ago, I was a speaker in a public meeting
orchestrated by USPS, and recommended that they take a lead role,
e.g., by acting as a national CA - certificate authority. Never
happened though. FCC issues lots of licenses...perhaps they
could issue online credentials too?
>>>>
>>>> Perhaps a "pilot" where you will also accept comments by
email, some possibly sent by "verified" humans if they understand
how to do so, would be worth trying? Perhaps comments on
"technical aspects" coming from people who demonstrably know how
to use technology would be valuable to the policy makers?
>>>>
>>>> The Internet, and technology such as TCP, began as an
experimental pilot about 50 years ago. Sometimes pilots become
infrastructures.
>>>>
>>>> FYI, I'm signing this message. Using OpenPGP. I could
encrypt it also, but my email program can't find your public key.
>>>>
>>>> Jack Haverty
>>>>
>>>>
>>>> On 10/5/23 14:21, David Bray, PhD wrote:
>>>>
>>>> Indeed Jack - a few things to balance - the Administrative
Procedure Act of 1946 (on which the idea of rulemaking is based)
us about raising legal concerns that must be answered by the
agency at the time the rulemaking is done. It's not a vote nor is
it the case that if the agency gets tons of comments in one
direction that they have to go in that direction. Instead it's
only about making sure legal concerns are considered and responded
to before the agency before the agency acts. (Which is partly why
sending "I'm for XYZ" or "I'm against ABC" really doesn't mean
anything to an agency - not only is that not a legal argument or
concern, it's also not something where they're obligated to follow
these comments - it's not a vote or poll).
>>>>
>>>> That said, political folks have spun things to the public as
if it is a poll/vote/chance to act. The raise a valid legal
concern part of the APA of 1946 is omitted. Moreover the fact that
third party law firms and others like to submit comments on behalf
of clients - there will always be a third party submitting
multiple comments for their clients (or "clients") because that's
their business.
>>>>
>>>> In the lead up to 2017, the Consumer and Government Affairs
Bureau of the FCC got an inquiry from a firm asking how they could
submit 1 million comments a day on an "upcoming privacy
proceeding" (their words, astute observers will note there was no
privacy proceeding before the FCC in 2017). When the Bureau asked
me, I told them either mail us a CD to upload it or submit one
comment with 1 million signatures. To attempt to flood us with 1
million comments a day (aside from the fact who can "predict"
having that many daily) would deny resources to others. In the
mess that followed, what was released to the public was so
redacted you couldn't see the legitimate concerns and better paths
that were offered to this entity.
>>>>
>>>> And the FCC isn't alone. EPA, FTC, and other regulatory
agencies have had these hijinks for years - and before the
Internet it was faxes, mass mimeographs (remember blue ink?), and
postcards.The Administrative Conference of the United States
(ACUS) - is the body that is supposed to provide consistent
guidance for things like this across the U.S. government. I've
briefed them and tried to raise awareness of these issues - as I
think fundamentally this is a **process** question that once
answered, tech can support. However they're not technologies and
updating the interpretation of the process isn't something lawyers
are apt to do until the evidence that things are in trouble is
overwhelming.
>>>>
>>>> 52 folks wrote a letter to them - and to GSA - back in 2020.
GSA had a rulemaking of its own on how to improve things, yet
oddly never published any of the comments it received (including
ours) and closed the rulemaking quietly. Here's the letter:
https://tinyurl.com/letter-signed-52-people
>>>>
>>>> And here's an article published in OODAloop about this - and
why Generative AI is probably going to make things even more
challenging:
https://www.oodaloop.com/archive/2023/04/18/why-a-pause-on-ai-development-is-not-the-answer-an-insiders-perspective/
>>>>
>>>> [snippet of the article] Now in 2023 and Beyond: Proactive
Approaches to AI and Society
>>>>
>>>> Looking to the future, to effectively address the challenges
arising from AI, we must foster a proactive, results-oriented, and
cooperative approach with the public. Think tanks and universities
can engage the public in conversations about how to work, live,
govern, and co-exist with modern technologies that impact society.
By involving diverse voices in the decision-making process, we can
better address and resolve the complex challenges AI presents on
local and national levels.
>>>>
>>>> In addition, we must encourage industry and political leaders
to participate in finding non-partisan, multi-sector solutions if
civil societies are to remain stable. By working together, we can
bridge the gap between technological advancements and their
societal implications.
>>>>
>>>> Finally, launching AI pilots across various sectors, such as
work, education, health, law, and civil society, is essential. We
must learn by doing on how we can create responsible civil
environments where AIs can be developed and deployed responsibly.
These initiatives can help us better understand and integrate AI
into our lives, ensuring its potential is harnessed for the
greater good while mitigating risks.
>>>>
>>>> In 2019 and 2020, a group of fifty-two people asked the
Administrative Conference of the United States (which helps guide
rulemaking procedures for federal agencies), General Accounting
Office, and the General Services Administration to call attention
to the need to address the challenges of chatbots flooding public
commenting procedures and potentially crowding out or denying
services to actual humans wanting to leave a comment. We asked:
>>>>
>>>> 1. Does identity matter regarding who files a comment or not
— and must one be a U.S. person in order to file?
>>>>
>>>> 2. Should agencies publish real-time counts of the number of
comments received — or is it better to wait until the end of a
commenting round to make all comments available, including counts?
>>>>
>>>> 3. Should third-party groups be able to file on behalf of
someone else or not — and do agencies have the right to remove
spam-like comments?
>>>>
>>>> 4. Should the public commenting process permit multiple
comments per individual for a proceeding — and if so, how many
comments from a single individual are too many? 100? 1000? More?
>>>>
>>>> 5. Finally, should the U.S. government itself consider, given
public perceptions about potential conflicts of interest for any
agency performing a public commenting process, whether it would be
better to have third-party groups take responsibility for
assembling comments and then filing those comments via a validated
process with the government?
>>>>
>>>> These same questions need pragmatic pilots that involve the
public to co-explore and co-develop how we operate effectively
amid these technological shifts. As the capabilities of LLMs
continue to grow, we need positive change agents willing to tackle
the messy issues at the intersection of technology and society.
The challenges are immense, but so too are the opportunities for
positive change. Let’s seize this moment to create a better
tomorrow for all. Working together, we can co-create a future that
embraces AI’s potential while mitigating its risks, informed by
the hard lessons we have already learned.
>>>>
>>>> Full article:
https://www.oodaloop.com/archive/2023/04/18/why-a-pause-on-ai-development-is-not-the-answer-an-insiders-perspective/
>>>>
>>>> Hope this helps.
>>>>
>>>>
>>>> On Thu, Oct 5, 2023 at 4:44 PM Jack Haverty via Nnagain
<[email protected]> wrote:
>>>>>
>>>>> Thanks for all your efforts to keep the "feedback loop" to
the rulemakers functioning!
>>>>>
>>>>> I'd like to offer a suggestion for a hopefully politically
acceptable way to handle the deluge, derived from my own battles
with "email" over the years (decades).
>>>>>
>>>>> Back in the 1970s, I implemented one of the first email
systems on the Arpanet, under the mentorship of JCR Licklider, who
had been pursuing his vision of a "Galactic Network" at ARPA and
MIT. One of the things we discovered was the significance of
anonymity. At the time, anonymity was forbidden on the Arpanet;
you needed an account on some computer, protected by passwords, in
order to legitimately use the network. The mechanisms were crude
and easily broken, but the principle applied.
>>>>>
>>>>> Over the years, that principle has been forgotten, and the
right to be anonymous has become entrenched. But many uses of
the network, and needs of its users, demand accountability, so all
sorts of mechanisms have been pasted on top of the network to
provide ways to judge user identity. Banks, medical services,
governments, and businesses all demand some way of proving your
identity, with passwords, various schemes of 2FA, VPNs, or other
such technology, with varying degrees of protection. It is still
possible to be anonymous on the net, but many things you do
require you to prove, to some extent, who you are.
>>>>>
>>>>> So, my suggestion for handling the deluge of "comments" is:
>>>>>
>>>>> 1/ create some mechanism for "registering" your intent to
submit a comment. Make it hard for bots to register. Perhaps
you can leverage the work of various partners, e.g., ISPs,
retailers, government agencies, financial institutions, of others
who already have some way of identifying their users.
>>>>>
>>>>> 2/ Also make registration optional - anyone can still submit
comments anonymously if they choose.
>>>>>
>>>>> 3/ for "registered commenters", provide a way to "edit" your
previous comment - i.e., advise that your comment is always the
last one you submitted. I.E., whoever you are, you can only
submit one comment, which will be the last one you submit.
>>>>>
>>>>> 4/ In the thousands of pages of comments, somehow flag the
ones that are from registered commenters, visible to the people
who read the comments. Even better, provide those "information
consumers" with ways to sort, filter, and search through the body
of comments.
>>>>>
>>>>> This may not reduce the deluge of comments, but I'd expect
it to help the lawyers and politicians keep their heads above the
water.
>>>>>
>>>>> Anonymity is an important issue for Net Neutrality too, but
I'll opine about that separately.....
>>>>>
>>>>> Jack Haverty
>>>>>
>>>>>
>>>>> On 10/2/23 12:38, David Bray, PhD via Nnagain wrote:
>>>>>
>>>>> Greetings all and thank you Dave Taht for that very kind
intro...
>>>>>
>>>>> First, I'll open with I'm a gosh-darn non-partisan, which
means I swore an oath to uphold the Constitution first and serve
the United States - not a specific party, tribe, or ideology. This
often means, especially in today's era of 24/7 news and social
media, non-partisans have to "top cover".
>>>>>
>>>>> Second, I'll share that in what happened in 2017 (which
itself was 10x what we saw in 2014) my biggest concern was and
remains that a few actors attempted to flood the system with
less-than-authentic comments.
>>>>>
>>>>> In some respects this is not new. The whole "notice and
comment" process is a legacy process that goes back decades. And
the FCC (and others) have had postcard floods of comments,
mimeographed letters of comments, faxed floods of comments, and
now this - which, when combined with generative AI, will be yet
another flood.
>>>>>
>>>>> Which gets me to my biggest concern as a non-partisan in
2023-2024, namely how LLMs might misuse and abuse the commenting
process further.
>>>>>
>>>>> Both in 2014 and 2017, I asked FCC General Counsel if I
could use CAPTChA to try to reduce the volume of web scrapers or
bots both filing and pulling info from the Electronic Comment
Filing System.
>>>>>
>>>>> Both times I was told *no* out of concerns that they might
prevent someone from filing. I asked if I could block obvious
spam, defined as someone filing a comment >100 times a minute, and
was similarly told no because one of those possible comments might
be genuine and/or it could be an ex party filing en masse for others.
>>>>>
>>>>> For 2017 we had to spin up 30x the number of AWS cloud
instances to handle the load - and this was a flood of comments at
4am, 5am, and 6am ET at night which normally shouldn’t see such
volumes. When I said there was a combination of actual humans
wanting to leave comments and others who were effectively denying
service to others (especially because if anyone wanted to do a
batch upload of 100,000 comments or more they could submit a CSV
file or a comment with 100,000 signatories) - both parties said
no, that couldn’t be happening.
>>>>>
>>>>> Until 2021 when the NY Attorney General proved that was
exactly what was happening with 18m of the 23m apparently from
non-authentic origin with ~9m from one side of the political aisle
(and six companies) and ~9m from the other side of the political
aisle (and one or more teenagers).
>>>>>
>>>>> So with Net Neutrality back on the agenda - here’s a simple
prediction, even if the volume of comments is somehow controlled,
10,000+ pages of comments produced by ChatGPT or a different LLM
is both possible and probably will be done. The question is if
someone includes a legitimate legal argument on page 6,517 - will
FCC’s lawyers spot it and respond to it as part of the NPRM?
>>>>>
>>>>> Hope this helps and with highest regards,
>>>>>
>>>>> -d.
>>>>> --
>>>>>
>>>>> Principal, LeadDoAdapt Ventures, Inc. & Distinguished Fellow
>>>>>
>>>>> Henry S. Stimson Center, Business Executives for National
Security
>>>>>
>>>>>
>>>>>
>>>>> On Mon, Oct 2, 2023 at 2:15 PM Dave Taht via Nnagain
<[email protected]> wrote:
>>>>>>
>>>>>> All:
>>>>>>
>>>>>> I have spent the last several days reaching out to as many
people I
>>>>>> know with a deep understanding of the policy and technical
issues
>>>>>> surrounding the internet, to participate on this list. I
encourage you
>>>>>> all to reach out on your own, especially to those that you can
>>>>>> constructively and civilly disagree with, and hopefully
work with, to
>>>>>> establish technical steps forward. Quite a few have joined
silently!
>>>>>> So far, 168 people have joined!
>>>>>>
>>>>>> Please welcome Dr David Bray[1], a self-described "human
flack jacket"
>>>>>> who, in the last NN debate, stood up for the non -partisan
FCC IT team
>>>>>> that successfully kept the system up 99.4% of the time
despite the
>>>>>> comment floods and network abuses from all sides. He has
shared with
>>>>>> me privately many sad (and some hilarious!) stories of that
era, and I
>>>>>> do kind of hope now, that some of that history surfaces,
and we can
>>>>>> learn from it.
>>>>>>
>>>>>> Thank you very much, David, for putting down your painful
memories[2],
>>>>>> and agreeing to join here. There is a lot to tackle here, going
>>>>>> forward.
>>>>>>
>>>>>> [1] https://www.stimson.org/ppl/david-bray/
>>>>>> [2] "Pain shared is reduced. Joy shared, increased." -
Spider Robinson
>>>>>>
>>>>>>
>>>>>> --
>>>>>> Oct 30:
https://netdevconf.info/0x17/news/the-maestro-and-the-music-bof.html
>>>>>> Dave Täht CSO, LibreQos
>>>>>> _______________________________________________
>>>>>> Nnagain mailing list
>>>>>> [email protected]
>>>>>> https://lists.bufferbloat.net/listinfo/nnagain
>>>>>
>>>>>
>>>>> _______________________________________________
>>>>> Nnagain mailing list
>>>>> [email protected]
>>>>> https://lists.bufferbloat.net/listinfo/nnagain
>>>>>
>>>>>
>>>>> _______________________________________________
>>>>> Nnagain mailing list
>>>>> [email protected]
>>>>> https://lists.bufferbloat.net/listinfo/nnagain
>>>>
>>>>
>>> _______________________________________________
>>> Nnagain mailing list
>>> [email protected]
>>> https://lists.bufferbloat.net/listinfo/nnagain
>>
>>
>>
>> --
>> Please send any postal/overnight deliveries to:
>> Vint Cerf
>> Google, LLC
>> 1900 Reston Metro Plaza, 16th Floor
>> Reston, VA 20190
>> +1 (571) 213 1346
>>
>>
>> until further notice
>>
>>
>>
>
> _______________________________________________
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--
Oct 30:
https://netdevconf.info/0x17/news/the-maestro-and-the-music-bof.html
Dave Täht CSO, LibreQos
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