FCC won’t force all of Title II “net neutrality” regulations on carriers, but “we don’t know where things go next”

This article may contain personal views and opinion from the author.

A lot of people and a lot of businesses were cheering the FCC’s predictable 3-to-2 vote to classify the internet as a utility, and thus apply Title II regulations which govern traditional telecommunications services. The dawn of net neutrality is at hand, or so say the proponents.

I can forgive a lot of the younger folks not understanding what Title II enables the FCC to do. These regulations were written and implemented in the 1930s, signed into law as the Communications Act of 1934 when telephones were the leading edge of consumer technology. That was only 81 years ago, surely those provisions will be an easy application to 21st century technology where a lot people do not know what a dial-tone is, or a step-switch, or a twisted pair.

The older folks though? Do you really need to be reminded of the absolute tangle traditional telecom services are to this day due to the absolute maze of federal and state regulations? You know, those rules that dictate how service is provided, where service may be provided, when service may be provided, what fees are attached, and how much the service itself will cost?

What could possibly go wrong? All data will be equal, that’s good right?

300 pages

I get it, it sounds good, it “feels” good. Joe Q. Public doesn’t have to worry about his YouTube feed or Netflix movies getting buffered or potentially blocked. The problem is that no one knows for sure how it will play out, not even the FCC. I can tell you this though, the internet has been open and unhindered by nearly all regulation in the free world, and it has ushered an unprecedented era of economic growth, technological innovation, generated unheard-of amounts of personal wealth, and unbridled levels communication. It is a shining example of what could be called the ultimate open-source project.

The arguments for net neutrality aren't technical, and they aren't even business arguments. Yet, they espouse this notion of “free and open” for all. If that is really the case, it shouldn’t take 300 pages of regulations to “help” a system that isn’t broken. Of course, no one but the FCC knows what those regulations are, because they were secret before the vote, and given the modus operandi in Washington, DC, I would be surprised if all five of the voting commissioners actually read them. The rules will hopefully be published in the early part of this week.

After the vote, FCC Chairman Tom Wheeler said in a press conference that the regulatory body was looking at what he termed as “bright line” issues (more on the non-bright line stuff later) – blocking, throttling, and paid prioritization, “…we know about those issues. But we don’t know where things go next.” (emphasis added)

The good and bad from the past

I don’t need to know where “things go next” based on where things have been. Are you familiar with “plain old telephone service?” Otherwise known as POTS, this basic type of service falls under Title II regulations. These rules empower the FCC, and the FCC uses that power with a heavy hand to this day (81 years later), to dictate pricing, availability, and “just and reasonable practices” of this nation’s telephone system.

At the time when Title II was implemented, there was one major phone company, Ma Bell (the old AT&T), and a few regional providers like GTE (General Telephone). In the lead up to, and aftermath of World War II, one of the major priorities was to ensure equal access of service as the country grew, not that there was a lack of demand for service, but in the face of a then-yet undissolved monopoly, the government laid down some ground rules to ultimately ensure that whenever and wherever POTS was needed, it would be provided. That is still the law of the land today, and it is not unreasonable given how the technology operates.

How the telephone is used by business is heavily regulated. Newer rules put a welcome clamp down on telemarketers, and I am certain that very few people are upset about that. With every ultra-tight rule comes leakage though, and anyone that has a hardline phone knows that auto-dialers spoof caller ID systems and call people, even if they are on the official “Do Not Call” list.

These rules for POTS do not change very often because use of facilities based services have plateaued or are on the decline. Prices and features must be filed with the FCC and a state’s public utilities agency for review before they can be formally implemented. Those same rules go beyond consumer services, they also play a role in the back-end services businesses use. The vote now casts what was once a quick-to-respond to market conditions industry on to rails that must now pass scrutiny with another master, as interconnection agreements between providers will now be regulated, and that includes mobile.

Title II has not been rewritten

The FCC says it will not exert many restrictions Title II allows upon the internet providers and wireless carriers, but therein lies the rub. The FCC did not, and cannot re-write Title II – only Congress can do that, and given the impact on interstate commerce this ruling is sure to have, Congress is sure to make a fuss since it is deciding body on matters of interstate commerce. The fact that the FCC says it will not enforce certain rules or guidelines related to Title II should not give anyone a warm and fuzzy feeling – case and point, when was the last time you believed a politician?

I won’t go on that rant (though I’m dying to), instead I will point out what all this may mean for the consumer. The possibilities of what we face are not guaranteed because remember, “we don’t know where things go next.” First, one must ask, should certain types of data have priority? The answer is an absolute, “yes” and I will start with fundamental features that are just becoming available, or are fairly recent additions to wireless service.

Why data needs to be prioritized

Do you enjoy HD voice on your carrier thanks to Voice-over-LTE? Do you know why the audio is so clear, and overall a higher quality? Because VoLTE is nothing more than Voice-over-Internet Protocol (VoIP). VoIP is a method of transporting voice calls over a data network, rather than via a circuit switched call. In today’s reality, most, if not all of our traditional calls have some type of IP backhaul, but even then this matter is still relevant.

In the past, VoIP was commonly associated with quality of service (QoS) problems. Part of the reason for that was the networks did not always lend proper priority to the voice packets of data, so the result would sometimes sound like jittering, clipping, or lost bits of audio altogether. The reason why VoIP works so well nowadays is because the protocol often overprovisions network capacity and ensures the voice traffic has priority. In other words, the voice traffic is given plenty of space and green lights along its path. The result is crystal clear calls.

I’m not talking about massive amounts of bandwidth, but that doesn’t matter anymore. Under net neutrality, all data will simply get in line, and it will move as fast as it can based on the available bandwidth in a given pipeline. The network owners will not be permitted to throttle some packets for sake of another based on content. So, if some of your favorite services degrade due to what used to be easily managed congestion periods, don’t fret, you got equal data for all bro!

How about Facetime or Skype Video calls? You like those don’t you? Well giving those applications priority through traditional ICMP (Internet Control Message Protocol) routing methods won’t mean as much since the network owners cannot prioritize that traffic either, but don’t worry, at least that email didn’t have to wait an extra few milliseconds.

The question of a flood of ultra-high bandwidth content

In my previous example, I only focused on voice and peer-to-peer type video, and I know there are limits to the ubiquity of those applications, not everyone uses Skype or Facetime, and voice activity has been stagnant. Given that, one might argue that our networks have the capacity to make all this stuff work. That could be true for right now, but know this, streaming a 1440p YouTube video on your quad-HD smartphone requires about 6-10Mbps of throughput. Ultra-HD 4K streaming content requires about 15-20Mbps.

Since all data is to be “equal,” all that is needed is for a new service to start offering something extravagant, like a “4K-Only Video Flicks” type service. With proper marketing and a guaranteed low-information consumer base that just wants to see what 4K video is like, the data requests to stream this content en masse could choke a service node in no time (never mind the fact that very few people have gear capable of actually processing the stream), as the throughput requirements are 10-times greater than 1080p video. The opportunity is there, and someone is madly hammering out code to launch just such a portal because all the data is equal.

Traditional 1080p needs only about 2Mbps when properly managed and prioritized. We are on the crux of a lot of advanced content being widely available. The consumer hardware and content is walking hand-in-hand, but our networks are not and “we don’t know where things go next.”

Implications for mobile – read between the lines

The FCC says it will not get into pricing permissions with the carriers over new plans that Title II empowers the regulator to do, if it so chooses. Whatever is not deemed a “bright line” item, the FCC will apply a “standard for future conduct,” whatever that means. To that point, let us look again at POTS. I still maintain a POTS line because I’m just old-school like that and its reliability is still unmatched in my opinion. The price of traditional telephone service has not gone up or down by any appreciable amount in decades. Why is that? Because the telephone companies have to file tariffs with the state and the FCC before changes to prices or features can be made.

Julie Veach is head of the FCC’s Wireline Competition Bureau, and for the wireless carrier concerns she says, “There is no requirement to come to the FCC to seek approval. There are opportunities to do so if a provider wants to.” Why might T-Mobile or Verizon want to talk to the FCC about a new price plan? Well under the ambiguous “standard of future conduct” concept, the FCC could offer an “opinion” about a plan and whether it meets that conduct clause.

“There are opportunities to do so...” In any given scenario, these regulations will increase the cost of doing business, and that means either slowing the rate of growth to maintain capital expenditures, or cut a business’ most expensive asset (or liability) item: the employee.

You are probably thinking that could be a good thing, a carrier arguably won’t go to the FCC with a rate increase proposal. What you overlook, however, is that the carrier is not incented to go to the FCC with a plan to lower rates either. Why would they? They can keep their margins where they are, slowly (or suddenly) bow out of two-year contracts, maybe tighten up the equipment financing options, and leave things where they are. If another provider tries to get into a low-ball price war, the competition can simply file a grievance declaring “unreasonable advantage” or whatever language is chosen to cite the “future conduct” standard – but hey, equal data.

Of course, none of that matters because according to the FCC’s general counsel, Jonathan Sallet, the regulator could just “decide on its own” that a new plan fails to meet the future conduct standard. Future practices and standards will be judged on a case-by-case basis. So again, why would a carrier offer a new plan ever again?

The implications of this vote are far more reaching than anyone is giving credit, and frankly, I’m astonished at the lack of vision from the tech corridor. “Utilities” are the most regulated entities in the country. The “feel good” types that are cheering, “Yay! All data is equal, because, yeah man, data, it needs to be equal,” are not thinking things through. None of this has to do with your personal data use, but it may very well impact that use because “we don’t know where things go next.”

All services are on the table now

Title II also regulates services, meaning that a company that makes commercial use of a “utility” is free game to fall under scrutiny. Remember, the FCC cannot rewrite Title II, so it has a de facto open door to play a role in the services we use on these data networks, including Google, Facebook, Twitter, your favorite streaming radio service, your email, et al. Don’t believe me? Look up the “fairness doctrine” from the days of radio prior to the 1980s.

Cautious proponents of net neutrality, like Google, have a new headache to worry about now. Google Fiber is now a "utility" and will become a prime target of other utilities. All it will take are formal complaints that the search engine is “unfairly” leveraging ad revenue from other commercialized services that use other parts of the internet (a utility) to suppress prices for services in select markets. Google has flourished in an open and unregulated internet, and while I know Larry Page and the gang are doing great things, they are better off with Tier 1 providers on their side, than against. Facebook, Twitter, Yahoo!, TV programming delivered over the internet, et al, can all be shepherded under Title II in some way.

“Zero-rate” type services are not currently on the FCC’s radar, so AT&T's sponsored data program, and T-Mobile customers that like to stream music for free do not have anything to be worried about, at least until someone changes their mind. Roger Sherman heads up the FCC’s Wireless Telecommunications Bureau and says it “would be premature” to state if “certain future plans” would be permitted or not. That means sponsored data may not be permitted, and perhaps other “zero-rate” feature initiatives will go under a bureaucrat’s microscope first. "Would be premature," if that does not sound like a bureaucrat looking to sink his teeth into something in order to "help," I don't know what is.

The reason why this matters to wireless, and to wireless consumers, is that mobile providers have fast become a person's primary access point to the internet and all the services available on a mobile device. Besides, once the signal hits a tower, it’s all riding on fiber and copper anyway. Those that argue American broadband initiatives have not kept pace with counterparts in parts of Europe and Japan are overlooking the size of the American continent, and what it takes to build and maintain connectivity on such a vast scale in an area with a fraction of the population density. A mile of fiber in the US serves far fewer people than a mile of fiber pretty much anywhere in Western Europe or Japan. Placing a mile of double-strand fiber costs roughly $30,000 to $50,000, and that still does not account for all variables. Take Manhattan, New York City, it is a little over 13 miles long. You can bet that there is more than a few hundred pairs of fiber running through that borough, but just 100 pairs would cost a conservative $50 million to install (maintenance is another issue). Scale that investment, and it represents billions of dollars of infrastructure. Believe me, the providers want you using the net.

The 300 pages of rules are expected to be published early this week, but I say again, so what? This vote on Title II is an invocation of ad hoc law and ad hoc regulation of an industry that has flourished without such constraints.

As long as the carriers, and the services we use abide by some abiguous “future conduct” rule, I guess we’re good to go right? Then again, to coin the low-confidence-inspiring words so aptly uttered by FCC Chairman Tom Wheeler, “We don’t know where things go next.”

references: FierceWireless and The Wall Street Journal



1. TerryTerius unregistered

You could've simply typed "I'm anti-regulation, I believe it hurt innovations and the government ruins whatever it touches." That would've saved a lot of time and been more to the point. Since most of this article was insinuation and assumption anyway. Though I will concede that you did raise a few important questions. Granted, I'll agree there is/was a more effective method for preventing ISP's from abusing their positions of dominance and charging whatever they like for sites depending on traffic and bandwidth consumption. Break up the ridiculously huge monopolistic companies that are Comcast and Time Warner. If the entire concept of the free market is that "competition is good". Then having close to none in the country must be the antithesis of that right?

2. Maxwell.R

Posts: 218; Member since: Sep 20, 2012

Time Warner and Comcast are not monopolies as ISPs, they entered the market as a result of the Telecom Act of 1996. They are not even Tier 1 providers which gets hammered by Title II the worst. Again, the net neutrality wave of protest against TW and Comcast is due to a crappy customer experience, not any technical or business consideration. There is no major market that does not have more than one choice for connectivity. I looked up three of the smallest towns I could onhttp://www.broadbandmap.gov/ and still found more than one choice for each. If the goal was to lay waste to TW and Comcast, then why invoke Title II to make everyone constrained?

4. TerryTerius unregistered

That's true on paper. In reality it's very different. I live in Marietta GA, just outside of Atlanta. Your options are exactly as follows: AT&T Comcast. That's where it stops. At least it does for anyone who doesn't own a house. This same story is repeated throughout most of the country, only swapping out Time Warner, Century link, Verizon, Cox & Charter depending on where you live. Yes, there are a few small ISP's scattered here and there but that isn't true for most markets and most Americans get their internet a small handful of companies. Many of those smaller ISP's are less expensive, but they also offer terribly slow internet thus driving many people to sign up with a larger company. If Comcast & Time Warner merge and become pretty much the only option in a whopping 36 states, this will only get worse. On top of that, it was blatantly obvious (Comcast themselves basically said it) that there was no intention to lower prices if the merger is approved. There is no real choice for internet providers for the most Americans, and you know that as well as I. This is especially true in major cities, and once you consider the fact that the pricing is very close for most of these companies it becomes even more clear that something is wrong. The entire reason this was needed was that AT&T & Comcast were publicly stating they intended to introduce things such as: Sponsored Data: Essentially pay to play. Companies that can afford it will get their content through to you without caps, companies that cannot couldn't and would suffer as a result. Paid Peering: Similar concept, larger companies can pay for more direct and faster connections to customers (which is new for consumer companies). This is EXACTLY what Comcast and the other major companies wanted, what the FCC just effectively blocked. There is no logical argument that their plans would've had a positive effect on the state of competition in our country. The destruction of Net Neutrality as a concept was already underway. Look at the whole fiasco with Netflix and Comcast as a perfect example of why this would be terrible. Your argument is sound on paper. In reality, it's simply untrue. The wave or protest was because of programs (like the ones I mentioned) that would've effectively created a system where the richest content providers thrived, the start-ups and smaller brands couldn't have competed. The fact that TW & Comcast have crappy service only makes it worse, and the fact that they already over-charge because they're the only game in town in many cities/towns isn't going to be alleviated if the two merge and become even bigger. That's what this protest was about.

8. Maxwell.R

Posts: 218; Member since: Sep 20, 2012

And Title II does exactly nothing to change the choices you cite for Marietta. Sponsored data was a wireless solution which would incent customers to use a service, it is not unlike dialing an 800-number. Your argument over paid peering is akin to someone that thinks they should not pay for more gas if they drive more. I'll spin the argument another way, the FCC just did AT&T, Verizon, Level 3, Sprint, etc, a favor - these companies with autonomous system backbones know the Title II regulations in-and-out. WIth that, they will use every rule to thwart new services from "providers" like Google, Facebook, pick-a-web-page or streaming video idea. Comcast and TW are stuck in the middle because their little networks are not autonomous systems in their own right. T-Mobile could get the short end of the stick too because it does not have any facilities based backbone like AT&T, VZ, and Sprint.

13. TerryTerius unregistered

Yeah, I have to disagree with your stance. Sponsored data was a way for AT&T to tax companies that can afford it, price out those that can't and would have inevitably lead to the inability of small companies and start ups to compete. That corporate bylines wasn't about providing incentive to customers makes zero sense. It was a pay-to-play plan. A damn near textbook example. And no, your analogy is wrong. I own my car. I'm the only one that uses my car. Nobody else has access to it, relies on it, or needs it in any way. The website is much more akin to the gas itself, with the ISP's being the gas station. Your analogy is off, because the gas station was charging those who provide the gas more in order for them to bring it to market. The customer isn't being taxed for "using more gas". The ISP's would be taxing the companies that provide the gasoline in the first place, in order to let them sell it through their network of gas stations. I'll never agree to a system that corrupts the idea of data being treated equally, because the ONLY alternative is for ISP's charging web based companies for access to their network. OR, charging the customer extra to access certain sites. Those are literally the only other two choices. I'm fundamentally against that, since the web is more of a necessity than a privilege now-a-days. And corrupting the ability of small players to bring their ideas to the web by making it too expensive for them to do so would be devastating. Facebook, Wikipedia, Google. They were all start-ups at a time. If it wasn't for net neutrality, they would've never had a chance to grow into what they are today. How many small sites provide information about history? Culture? Serve as databases for all sorts of random information and act like a worldwide library for us? The internet IS our collective knowledge, and that's more valuable than the ability to monetize access as much as possible. Once you attain a library card, they don't start charging you to take out different books based on how popular they are. It doesn't charge you for accessing different kinds of media, and if it did we'd have even fewer educated people in a society that desperately needs MORE access to knowledge, free trade of ideas and exposure to other cultures. Not less. The web shouldn't be treated any differently. I get your position. I just don't agree with it. I'll end this argument here, because it's plain we wont agree and this is pointless. But, I do bid you a good day. I have no ill will towards you :) I just think you're misguided.

18. Maxwell.R

Posts: 218; Member since: Sep 20, 2012

Your car is akin to your smartphone or computer. You do not own the road, you pay for it through taxes (some of which paid through gas taxes). If you drive more, you consume more (of everything), gas, oil, tires, ad infinitum. To your final point, this was the longest editorial I've written. I believe in active discourse, and love legitimate debate. Keep reading, I will have a follow-up to this in a week or two, discussing more "what-ifs" about net neutrality. No ill will here either. Have a great week!

5. WillieFDiaz

Posts: 127; Member since: Dec 22, 2010

Wow, written like a Comcast and Verizon employee who hates some basic regulation to prevent one major cable and one major telephone provider from gettingnin bed with their other best friends and deciding for America what is actually best.

7. TerryTerius unregistered


10. Maxwell.R

Posts: 218; Member since: Sep 20, 2012

Place an order for POTS with your local telco and measure the frustration level, and observe the whole process, that is what Title II opens the door to. Make sure you pick an LD carrier too.

6. TerryTerius unregistered

To put it another way, if your argument was valid we would already have some of the fastest internet in the world. Given that we're not even in the top 10 that kind of invalidates the idea that it's "regulation" that's holding companies back from giving us the fastest possible speeds. It's huge companies with little reason to invest into upgrading their fiber and networks due to a total absence of competition in most of their territory that has lead to the stagnation. That's painfully clear, especially since this net neutrality regulation is brand new. What's the excuse for the past 20 years when it didn't even exist? Yes we're a large country. We're also ludicrously wealthy compared to 99% of the planet, with companies that had deep enough pockets to up their game. There's no excuse for our pathetic internet speed.

9. Maxwell.R

Posts: 218; Member since: Sep 20, 2012

See my point about the facilities in place, the distances covered, and population density. Also, Europe completely rebuilt its infrastructure after WWII, the US original "footprint" is over 100 years old.

12. TerryTerius unregistered

I'm aware of your point. I'm saying that's irrelevant. There was nothing preventing ISP's from lobbying for a nationwide upgrade or from them taking matters into their own hand. Like I said, if the whole thesis of your argument is that they will take matters into their own hands and they know what's best, they showed what they wanted by doing nothing for decades. Their interest is only in the money, not serving their customers the fastest possible internet. Why do so when they have no where else to go for service? Yes, i'm aware companies have bottom lines. But that's a poor argument for stagnation. Stagnant means the status quo is maintained. They were happy with the system as it was, and things became that way because of lack of investment and competition.

17. Maxwell.R

Posts: 218; Member since: Sep 20, 2012

It's not irrelevant at all. The FCC's vote was about inserting itself in the backhaul that managed **all** data traffic. TW and Comcast are nothing more than local portals to the "internet." Wireless carriers have the added burden of managing bandwidth on much more volatile spectrum versus hardlines. Your complaints are certainly legitimate, Title II will not fix any of it. You will get no extra choice, and expect to see a stall in what was a trend of decreasing prices for data in wireless. On the back end, Level 3 is one of the Tier 1 providers that has complained about choke-points in peering agreements with other providers like Verizon, AT&T, Cogent, and XO. Yet, Level 3 operates three distinct autonomous system backbones of its own (L3, Global Crossing, and Genuity). Verizon, Sprint, and AT&T each operate one. Where Level 3 gets fuzzy in detail is if it is taking peering policies in aggregate to its 3:1 ratio of networks. On any scale, bandwidth has a limit, and the limits vary by market and provider. The FCC would rather see everyone choke on it, or, it is a precursor to try and force all the providers to bond all the bandwidth together.

11. mschmal

Posts: 23; Member since: Sep 01, 2011

Excuse me but I live in the mostly densely populated state, NJ and I only have one choice of for wired broadband. Comcast. DSL at up to 6 mbps is not really broadband. Also you miss the whole point of net neutrality. Suppose that Comcast wants to boost revenue for Hulu which it owns. Without net neutrality, Comcast could make Hulu the only usually video services available to its customers. Everything else could just buffer. And me as a Consumer? I have to suffer because there is no real broadband choice in my town.

15. Maxwell.R

Posts: 218; Member since: Sep 20, 2012

If this were about one provider, then such a sweeping vote would not have taken place, scooping up mobile in the mix, and creating an environment where a carrier may be forced to "ask permission" to roll out a new rate plan.

14. Slammer

Posts: 1515; Member since: Jun 03, 2010

I'm not huge with excessive government intervention, but when I hear the ISP providers being the largest opponent of NN, one has to take a firm look at what the basis for this is. I have a hard time believing that they are fighting against it for the good of the customer. As competition is dwindling, we are envisioning more consumer constriction. An oligopoly is obviously not condusive to a customer friendly market. I remember having 7 choices for an ISP. 3 is all I have now. And even though I can agree that up to this point the net hasn't been an issue, the competition is indeed dying and I see an open door for collusion and ISPs abusing the control. I would rather have a "publically" appointed government oversee the net rules rather than a "private" sector with no rules or regulations. John B.

16. Maxwell.R

Posts: 218; Member since: Sep 20, 2012

So where businesses have failed, impose new rules that ultimately favor the existing utilities?

19. Slammer

Posts: 1515; Member since: Jun 03, 2010

Businesses fail for many reasons. To blame government and/or regulations on the failures, is subjective. I can agree that government is not most efficient entity. But, I get tired of business failures being blamed on government. What about countless companies flourishing with regulations? Are they operating under a different government? Keep it honest and you won't have to worry about the government. John B.

20. Maxwell.R

Posts: 218; Member since: Sep 20, 2012

I didn't blame the government for business failures per se, but where you recounted having a decreasing number of options for service, a product of a free market system of competition, you then advocate the government to step in to "fix" something. Name a single company in the US that is "flourishing" under heavy regulation.

21. Slammer

Posts: 1515; Member since: Jun 03, 2010

Who said anything about "heavy" regulations? I said regulations.The strong survive while the weak perish. It's been this way since the beginning of time. The fact remains that the free market has allowed the two largest carriers to manipulate the industry in their favor. A cartel if you will. Power often leads to abuse. Just as we can easily accuse the government for such actions, we excuse the carriers for doing the same? I think as consumers, we are asking for regulations to be imposed on an industry that hasn't played fair. As consolidation continues, consumer complaints have risen exponentially. From 2013-2014 alone, complaints towards carriers have risen 16%. Many have gone unresolved and with the landmark ruling of arbitration over class action suits(which was heavily supported by carriers), the folcrum point as tipped in favor of the corprations. While there are advantages to arbitration, ultimately the financial burden has been placed in the consumers hands. Most will elect to forego any further pursuit due to costs. Who benefits from this? Do you think AT&T and Verizon are going to fail due to added regulations? They can threaten to cease building and expanding on their networks all they want. I'm sure this will only add to more government intervention which is what they are fighting against in the first place. And I'm quite sure shareholders will have something to say as well. Or maybe they will just close their doors? John B.

* Some comments have been hidden, because they don't meet the discussions rules.

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