FCC Comments on “Specialized Services” and Wireless Open Internet Rules

Media Access project, as counsel to the Benton Foundation, Center for Media Justice, Consumers Union, New America Foundation, and Public Knowledge (collectively “Public Interest Commenters” or “PIC”), respectfully submits these comments in response to the Public Notice released by the Commission’s Wireline Competition Bureau and Wireless Telecommunications Bureau in the above-captioned dockets. Public Interest Commenters respectfully suggest that the two issues set forth for comment in the Public Notice—the treatment of “specialized services” and the application of Open Internet rules to mobile wireless platforms—are not “under-developed,” as these questions already have been raised and discussed in this proceeding. Nevertheless, Public Interest Commenters welcome this opportunity to recount briefly their prior positions, explaining herein that specialized services must be a limited category (if recognized by the Commission at all) and that mobile wireless broadband networks must be protected by Open Internet rules.