#MiamiTech wants Net Neutrality

Written by Auston Bunsen on 12th December 2017, 1:16 PM

Congressman Carlos Curbelo et al.

We are the founders & leaders of technology startups here in Miami. Collectively, we represent tens of millions of dollars in revenue and thousands of employees in Miami’s burgeoning tech scene. We have a deep understanding of web technology as it is essential to our livelihood. We are writing to ask you to help stop the repeal of Title II classification of ISPs. It is unfortunate that we currently face a difficult question: Should we (the U.S.A.) repeal Title II’s net neutrality protection or not?


We believe the answer is no. We should not repeal the Title II classification without a legitimate, well thought out replacement. As business owners, we understand the serious nature of regulation & it’s hampering effects on our ability to innovate. We believe these regulations are an exception to the rule. In 2015, the Title II classification of ISPs explicitly excluded more than 700 of the rules found in Title II regulation [1] for the exact reason of maintaining a “light touch” philosophy. Beyond the fact that it has indeed been a light touch approach, the most important thing to note is that there are guarantees that come with the current classification that are essential to maintaining a competitive environment for businesses like ours to thrive. Businesses like Clutch Prep which depends on open internet access to college students who use their platform to become the doctors of tomorrow [2]. Businesses like LiveNinja who depend on WebRTC communications to consumers across the entire country by customers like Apple, Samsung & HP [3]. Businesses like NomadsTV which provides OTT software to media companies [4].


Ajit Pai’s original dissent [5] expressed valid concerns. However, the last two years have come to show that they are not currently an issue. Things like Universal Service Fund taxes are not being imposed (at least not to our knowledge), the classification has not stopped or prevented zero rating (T-Mobile is a great example of the current protections being in place without disrupting innovation [6]). Many small local ISPs are not overburdened due to this classification [7], broadband prices have stagnated or decreased in price [8]. Meanwhile, access to broadband is growing [9] [10] and speeds are increasing [11].


We believe the internet has grown and provided economic opportunity unfettered by existing regulations. However, bad behavior has arisen among ISP’s covering the “last mile”: providers have tried to charge companies for access to their own customers [12],  they have been caught blocking services that customers have paid for [13] [14], and found throttling traffic they deemed to be unimportant [15].


Because the draft order repeals net neutrality rules altogether, it allows ISPs to block or throttle lawful content, or give the highest-paying websites and apps a better ability to reach customers’ devices or to favor Internet traffic from the ISPs’ own subsidiaries and business partners, all without any legal repercussions. This could be devastating to our livelihoods and have many implications in the long term.


We believe Chariman Pai can and should continue to have a light touch and maintain the current Title II classification while he crafts a legitimate, better-designed replacement that guarantees no blocking of content, throttling or paid priority while providing an even less intrusive regulation than is currently in place. This is the United States of America; we can do better.


Thank You,

Auston Bunsen, Lead Instructor at Wyncode Academy

Johanna Mikkola, Co-founder of Wyncode Academy

Juha Mikkola, Co-founder of Wyncode Academy

Ivan Rapin-Smith, Managing Director at Watsco Ventures

Rob Dyson, CTO & Co-founder of Willing.com

Rebekah Monson, Co-founder of WhereBy.us

Lu Martinez, Founder of StardomUp

Mary Wolff, CEO & Co-Founder, Spacewolff

Brian Breslin, Co-founder of SimCase

Ulises Orozco, CPO of Saving for College

Maria Derchi, Executive Director of Refresh Miami

Erik Mendelson, CEO of RecordGram

Otto Othman, CMO & Co-founder of Pincho Factory

Miles Varghese, SVP of Sales for Octopi

Guille Carlos, CTO & Co-founder of Octopi

Luc Castera, Founder of Octopi

Andrej Kostresevic, CEO of Nomads

Will Weinraub, CEO & Co-founder of LiveNinja

Emilio Cueto, CTO & Co-founder of LiveNinja

Alfonso Ligares, CDO & Co-founder of LiveNinja

Brian Brackeen, Founder & CEO of Kairos

Herwig Konings, CEO of InvestReady

Alex Nucci, CEO of Gramercy

Richard Grundy, CEO of Flomio

Jose Raasco, Founder & CEO of dotHealth

Marcio Souza, CEO & Co-founder of Clutch Prep

Alain Fontaine, CTO & Co-founder of Clutch Prep

Juan Bermudez, CEO & Co-founder of Coach-HQ


Larry Ho, COO of Ziro


1. Please see this: https://www.cnet.com/news/13-things-you-need-to-know-about-the-fccs-net-neutrality-regulation/

2. Profile on Clutch Prep: https://startupbeat.com/2014/09/featured-startup-pitch-clutchpreps-textbook-specific-videos-built-help-college-students-get-better-grades-id3959/

3. LiveNinja’s press: https://techcrunch.com/2016/05/04/liveninja-secures-a-further-2m-to-combine-live-web-chat-and-messaging/

4. Information on Nomads OTT product: http://nomads.co/product/whitelabelottvideo/

5. Ajit Pai’s 85 page original dissent on Net Neutrality order: https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-24A5.pdf

6. Get “free” streaming with a special plan from T-Mobile: https://www.t-mobile.com/offer/free-music-streaming.html

7. 40 small ISP’s in support of Net Neutrality: https://www.eff.org/files/2017/06/27/isp_letter_to_fcc_on_nn_privacy_title_ii.pdf

8. Broadband for America infographic: https://www.broadbandforamerica.com/uploads/2017/05/International-Broadband-For-America-Comparison-Brochure.pdf

9. Report on growing Gigabit internet effects: http://www.analysisgroup.com/uploadedfiles/content/insights/publishing/broadband_competition_report_november_2016.pdf

10. Report on adoption of Broadband in U.S.: http://www.pewinternet.org/2006/05/28/part-1-broadband-adoption-in-the-united-states/

11. Speeds are increasing for both fixed & wireless connections: https://www.statista.com/statistics/616210/average-internet-connection-speed-in-the-us/http://www.speedtest.net/reports/united-states/#fixed

12. Netflix v. Comcast debacle: http://www.zdnet.com/article/netflix-comcast-is-charging-us-for-access-to-our-subscribers/

13. AT&T was blocking FaceTime: https://www.washingtonpost.com/blogs/post-tech/post/atandt-lifts-facetime-restrictions-on-apple-iphones/2012/11/08/cbec36de-29de-11e2-b4e0-346287b7e56c_blog.html

14. ISP Madison River blocking VOIP traffic FCC ruling: https://apps.fcc.gov/edocs_public/attachmatch/DA-05-543A2.pdf

15. Comcast blocking / throttling legal peer-to-peer traffic: https://en.wikipedia.org/wiki/Comcast_Corp._v._FCC#Background