Bots and Form Letters Make It Nearly Impossible to Find Real FCC Net Neutrality Comments

 In U.S.
The Federal Communications Commissions’ public comment period on its plans to repeal net neutrality protections was bombarded with bots, memes, and input from people who don’t actually exist. The situation’s gotten so bad that FCC Commissioner Jessica Rosenworcel, as well as several members of Congress, including one Republican, have called for the FCC to postpone its December 14 net neutrality vote so that an investigation can take place.

The FCC seems unlikely to comply. According to an FCC spokesman, the FCC is zeroing in on legal arguments within those comments, effectively disregarding any outpouring of support for net neutrality from regular Joes. “The purpose of a rulemaking proceeding is to not to see who can dump the most form letters into a docket. Rather, it is to gather facts and legal arguments so that the Commission can reach a well-supported decision,” Brian Hart, the FCC’s head of media relations, tells WIRED. Now, the Commission is barreling ahead toward Chairman Ajit Pai’s plan to essentially allow internet service providers to speed up or slow down internet traffic however they please.

So, with the FCC declining to investigate its own comments, we decided to undertake an analysis of our own.

Yes, researchers have already sliced and diced the data. But parsing 23 million comments can quickly bend toward abstraction. How many of those commenters are real? How many are bots? How many were real, but using identical form letters drafted by advocacy groups?

For a better handle on just how broken the FCC comment system is, we went granular, analyzing all of the submissions that fell under a single name. We wanted a name that was common enough to produce a decent number of hits (so, you know, not Issie Lapowsky), but singular enough that we could actually mine them in a few days (tough luck, James Smith). We settled on Nicholas Thompson, WIRED’s editor in chief, and excluded any Nicks, or Nicholas Thompsons who also supplied a middle initial.

That left us with 39 results between May 11 and December 8 of this year. Using a combination of Facebook, public records tools like Spokeo and Nexis, and the good old fashioned telephone, we attempted to make contact with each of them. It’s far from a perfect or scientific sample, but it does help illuminate what the chaos in the FCC’s comments look like up close. Here’s what we found:

The Bots

Let’s start with the outright fakes, since they’re in some ways the easiest to sniff out. To find the bot Nicholas Thompsons in our sample, we enlisted the help of FiscalNote, a company that processes public comments on behalf of corporations to help them make sense of the policy landscape. Researchers at FiscalNote previously identified nearly one million comments as bot submissions, all of them opposing net neutrality. Each one followed the same paragraph pattern, stringing together 35 synonymous words and phrases in a particular order to form similar, but not identical, comments.

FiscalNote’s vice president of research Vlad Eidelman found six comments that fit that pattern among the 39 Nicholas Thompsons, all submitted over the course of eight days in May. They included strange grammatical formations, like in the example below:

Dear Chairman Pai, I am concerned about internet regulations. I
suggest the commission to repeal Tom Wheeler’s decision to control the
Internet. Internet users, rather than so-called experts, should be
empowered to enjoy whichever applications we want. Tom Wheeler’s
decision to control the Internet is a exploitation of the open
Internet. It ended a pro-consumer policy that functioned very, very
successfully for a long time with bipartisan support.

Four of the bots were attached to fake home addresses, according to public records searches. The one below was associated with an email address that’s available for purchase on emaildownload.org:

Chairman Pai: In the matter of the FCC’s so-called Open Internet
order. I want to recommend you to overturn The previous
administration’s decision to take over broadband. Internet users, not
Washington, should be free to purchase the applications we choose. The
previous administration’s decision to take over broadband is a
perversion of net neutrality. It ended a market-based policy that
worked very, very successfully for a long time with broad bipartisan
support.

Some bot-generated comments, though, used real names and addresses. Using the email address connected to one of these bot comments, we were able to track down one real Nicholas Thompson whose name and old address in Los Angeles were being used without his knowledge.

Thompson, who now lives in Portland, says he had submitted a pro-net neutrality comment to the FCC earlier this year. When we reached him by phone, he was angry to know that his authentic comment had been effectively cancelled out by a fake comment using his information. “That’s pretty messed up. It’s pretty sneaky on whoever decided to do that,” Thompson says. “I feel, for lack of a better term, just robbed of my voice.”

Confirmed Bots: 6

The Form Letters

Form letters are comments that advocacy groups draft for their members to submit en masse. According to Pew Research, only 6 percent of the roughly 23 million comments submitted to the FCC were actually unique. The rest were a combination of form letters and bots. The most popular form, submitted 2.8 million times, was a pro-net neutrality comment drafted by the advocacy group Battle for the Net. Eight Nicholas Thompsons submitted comments associated with Battle for the Net, each one linked to an authentic street address, though we couldn’t confirm their identities directly.

Here’s one of them:

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