The Comments Golden Frog Filed to the FCC

GF Seal

Last Friday, Golden Frog filed comments with the United States Federal Communication Commission in support of the Open Internet. We included feedback from our own customers to show how broadband Internet access providers are taking advantage of the current landscape to deny regular users the open, neutral, and uninterrupted service to which the Commission says they are entitled.

On Friday, Colin Nederkoorn, CEO of Customer.io wrote a blog post and posted a YouTube video about a test he performed on his supposedly blazing fast 75 Mbps Verizon FiOS service. It was extremely slow when watching Netflix. But, when Colin connects to VyprVPN and watches Netflix his speed would increase ten-fold from a paltry 375 Kbps to 3000 Kbps. The ten-fold increase in speed that resulted from encrypting his traffic and using Golden Frog’s network instead of Verizon’s. This speed increase is consistent with reports from other VyprVPN customers. We are in the competitive VPN industry so we continually work to manage and optimize our network so we can deliver the fastest VPN speeds in the world. It appears that Verizon is intentionally ignoring congested Internet backbone links in order to get Netflix to pay them. Internet access providers are intentionally mismanaging their networks to their own users’ detriment due to the lack of ISP competition in the United States.

Colin’s blog post went viral on social media and created more awareness about the service degradation that results from the lack of competition. We are grateful to Colin for helping expose Verizon and decided to include his example in our FCC filing. We urge the FCC to standup for consumers and to reclassify the broadband transmission component as a Title II telecommunications service.

In our FCC filing, we also show that a wireless broadband Internet access provider is interfering with its users’ ability to encrypt their SMTP email traffic. This broadband provider is overwriting the content of users’ communications and actively blocking STARTTLS encryption. This is a man-in-the-middle attack that prevents customers from using the applications of their choosing and directly prevents users from protecting their privacy.

The Commission must establish effective rules that prevent this type of behavior. Unless wireless and wireline broadband access providers receive a strong message that they can no longer throttle and block their users’ Internet traffic, these actions will continue, expand, and become the norm. Golden Frog calls on the Commission to truly restore the open Internet, enhance competition, protect user choice, and ensure users can keep nosy Internet access providers from intercepting their private information.

Executive summary of our filing to the FCC

Since there are no enforceable open Internet rules, broadband Internet access providers are currently throttling and locking Internet users’ traffic. These comments discuss two recent examples that show that users are not receiving the open, neutral, and uninterrupted service to which the Commission says they are entitled.

In the first instance, a customer of Golden Frog’s VyprVPN encrypted VPN service has proven that his Netflix traffic is being throttled on Verizon’s FiOS service. Colin Nederkoorn recently posted a YouTube video of a test he performed on his 75 Mbps service from Verizon that shows his Netflix connection increased from a paltry 375 Kbps to 3000 Kbps when he employed VyprVPN. This is a ten-fold increase that resulted from encrypting his traffic and using VyprVPN’s routing. This type of increase in speed is consistent with reports from other customers. Internet access providers are mismanaging their networks to their own users’ detriment.

In the second instance, Golden Frog shows that a wireless broadband Internet access provider is interfering with its users’ ability to encrypt their SMTP email traffic. This broadband provider is overwriting the content of users’ communications and actively blocking STARTTLS encryption. This is a man-in-the-middle attack that prevents customers from using the applications of their choosing and directly prevents users from protecting their privacy.

The Commission must establish effective rules that prevent this type of behavior. Unless wireless and wireline broadband access providers receive a strong message that they can no longer throttle and block their users’ Internet traffic, these actions will continue, expand, and become the norm. Golden Frog calls on the Commission to truly restore the open Internet, enhance competition, protect user choice, and ensure users can keep nosy Internet access providers from intercepting their private information.

Read the full text of our filing.