Testimony and Filings

ITIF Files Open Internet Reply Comments

September 15, 2014
| Testimony and Filings

ITIF filed open Internet reply comments Monday, urging the Federal Communications Commission to develop flexible regulation under section 706, allowing for innovation both at the edge and within the network itself. Many of the assumptions underlying arguments for Title II, utility-style regulation are ill-founded. Instead of giving in to over-blown fears, the Commission should allow for commercially reasonable prioritization that enables networks to support the ever-growing variety of Internet applications.

ITIF Files Comments Urging the FCC to Not Encourage Municipal Broadband Overbuilds

August 29, 2014
| Testimony and Filings

In Comments filed with the Federal Communications Commission today, ITIF urged the Commission to not encourage municipal broadband overbuilds. This high fixed-cost industry is driven by economics that cannot sustain increased competition through an injection of public money without imposing negative externalities on others. This fact, combined with the poor track record of attempted municipal networks as well as the availability of alternative opportunities to reduce the costs of deploying or upgrading networks means state laws restricting these networks are usually good policy and should not be preempted. Doug Brake, telecom policy analyst at ITIF, said, "when analyzing state restrictions on municipal networks you have to ask whether these networks benefit or harm the surrounding area. Where networks duplicate existing private infrastructure, it is likely they end up raising costs on others, justifying state restrictions."

ITIF Files Comments Supporting Proposed Comcast-TWC Merger

August 25, 2014
| Testimony and Filings

ITIF urged regulators to consider the dynamic and productive efficiencies that would come with a larger cable company. The proposed transaction will allow Comcast a larger footprint to recoup the large investments needed to maintain, improve, and operate its network as well as drive research and development and quickly scale innovations. These benefits come at virtually no cost to competition: with no reduction in horizontal competition and little reason to fear any effect on upstream markets, this acquisition is likely in the public interest.

Comments Advocating For a Flexible Interconnection Regime

August 8, 2014
| Testimony and Filings

ITIF filed comments in response to the House Energy and Commerce Committee's whitepaper on interconnection. We believe the successful growth and innovation in interconnection arrangements in the Internet space can be a good guide as we continue to move voice traffic onto IP networks. Recent interconnection disputes should best be seen as growing pains in the expansion of data-intensive use of the Internet and not distract from the success and innovation in a diversity of interconnection arrangements.

ITIF Comments on the ASCAP and BMI Consent Decrees

August 6, 2014
| Testimony and Filings

The purpose of copyright law is to establish a system that encourages the creation and dissemination of new works by providing authors with an incentive to create those works. There are many types of music services that provide consumers with access to the songs they love. From terrestrial radio to online subscription music services, each platform is governed by different rules that determine which types of royalties must be paid and how prices change from service to service. While policymakers created the U.S. music licensing system to provide fair compensation for artists, songwriters, and composers and to foster innovation, the current system often fails to do either. The Department of Justice (DOJ) should use the review of the American Society of Composers, Authors and Publishers (ASCAP) and Broadcast Music Inc.’s (BMI) consent decrees to begin the process of modernizing the way music copyrights are licensed in the digital age, kee ping an eye on innovation, competition, transparency, and fairness. The Performance Rights Organizations (PROs), such as ASCAP and BMI, are mired in a slow, complex system that fails to create competitive rates for compulsory licenses. While the onus to fix many of these issues ultimately resides in the halls of Congress, DOJ can sow the seed of change by pushing the PROs to adopt several directives as part of these consent decrees. DOJ requested comment on whether these consent decrees still serve an important purpose today. ITIF believes these consent decrees are still important to protect competition, because in their absence, the bulk music licensing world of the PROs is free to pursue monopolistic pricing. However, the DOJ can take steps to improve the consent decrees and to align them with technological breakthroughs and innovations of the digital age.

Comments to the NTIA on Big Data and Privacy

August 5, 2014
| Testimony and Filings

The Center for Data Innovation submitted comments recommending that policymakers restrict specific harmful uses of data, promote data reuse and sharing, and look to existing anti-discrimination law as a model for reducing data misuse. 

Comments to the Senate Finance Committee on Health Data Transparency

August 4, 2014
| Testimony and Filings

In response to a request for comment on health data transparency issued by members of the Senate Finance Committee, the Center for Data Innovation recommended that federal agencies make taxpayer-funded medical research data accessible in a timely manner, federal health care programs release granular payments data, and federal research agencies encourage data sharing across the health care industry.

Why UPP Pricing in the Contact Lens Industry Hurts Consumers and Competition

July 31, 2014
| Testimony and Filings

Rob Atkinson filed comments to the U.S. Senate Committee on Judiciary's Subcommittee on Antitrust, Competition Policy and Consumer Rights in regards to their hearing on pricing polices in the contact lens industry.

Letter in Support of the Social Security Commission Act of 2014

July 28, 2014
| Testimony and Filings

ITIF joined other leading think tanks in supporting the introduction of legislation designed to address the critical fiscal crisis facing Social Security. The bill, co-sponsored by Congressmen John Delaney (D-MD) and Tim Cole (R-OK), would create a bipartisan commission tasked with making recommendations to Congress, including proposed legislation, for achieving solvency in the Social Security trust funds for a period of at least 75 years.

ITIF Comments on the FAA Model Aircraft Rules

July 24, 2014
| Testimony and Filings

The FAA has interpreted its Model Aircraft rules too narrowly and should not create preemptive or prophylactic rules that limit the innovative technologies that represent the next-generation of model aircraft. Instead, the FAA's rules should mirror established model aircraft community’s voluntary safety criteria. In doing so, the FAA will adhere to Congress’s original intent and facilitate safety among model aircraft users who are experimenting with new technology and innovative aircraft. The FAA should also examine its arbitrary distinction between commercial and recreational unmanned aircraft.

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