growing range of services, content and applications. Consumers benefit from the increasedchoice created by the competitive forces of an open Internet.Guild members benefit from an open Internet both as content creators and consumers,who write and view news, commentary and entertainment, and participate in social networking.In addition to the benefits Internet freedom offers to our society, for content creators the Internetalso represents an independent and competitive distribution platform. While television and filmdistribution is controlled by a handful of powerful media companies, the Internet offers amedium through which anyone with a story can find an audience. An open Internet protected bynet neutrality will enhance job opportunities for Guild members and expand content offerings toconsumers.
Opposition to Common Carrier Status, is, in Effect, Opposition to Net Neutrality
As outlined in our initial comments on this NOI and discussed in the separate submissionof the Open Internet Coalition, the recent DC Circuit decision
Comcast v. FCC
makes clear thatthe Commission will be unable to protect a free and open Internet by relying on Title I ancillaryauthority. It is therefore necessary for the FCC to reclassify broadband transmission as a“telecommunications service” subject to regulation under Title II in order to enforce netneutrality. We respectfully disagree with the Industry Guilds that a “non-common carrierapproach” will allow the Internet to remain “a free and open platform that promotes innovation,investment, competition, and users’ interests.”
Further attempts by the Commission to rely onancillary authority under Title I to protect a free and open Internet will inevitably be met withcontinued legal resistance and will prolong regulatory uncertainty.
See Comments of AFTRA, et al., In the Matter of a Framework for Broadband Internet Services, GN Docket No.10-127, p. 9.