Submitting this today. Let me know if there's anything I should change. I tried to be as concise as possible.
Editing this live; please make sure that you are checking this version for the current draft if you intend to submit feedback. The PDF/JPG copy is for people who do not want to use Gdocs.
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Here are my suggested edits from the start of the document to the ddos mitigation section header.
Strike through is original text to remove, bold is what I added.
Background section
No edits
Internet Backbone Companies
Tier 1 ISPs are enormous companies that are traditionally defined as having connections to all other Tier 1 ISPs . Any two computers connected anywhere in the world will almost certainly need to utilize a Tier 1 ISP to communicate. If Tier 1 ISPs start to block connections to or from specific computers, that computer will find itself disconnected from significant swathes of the worldwide Internet.
I have experienced Tier 1 ISP censorship first hand. Until 2022, it was unheard of for these ISPs to censor specific companies,
, as their businesses enjoy very little public scrutiny and as they have traditionally understood their role as important and neutral services. This
era ended
with when Cogent, a Tier 1 ISP based out of the District of Columbia, under CEO Dave Schaeffer,
censored my business by disconnecting me from their backbone infrastructure.
Cogent has enjoyed significant income from the US Federal Government, both in contracts for providing Internet access to government agencies, and in grants for the deployment of new Internet infrastructure.
Tier 1 ISPs like Cogent enjoy very little public scrutiny, which has allowed them to increasingly engage in such censorship unchecked.
Back in the telephone era of the 1980s, the idea that AT&T (Ma Bell), would be have been allowed to disconnect the phone lines of their domestic political enemies and refuse them telephone service was unthinkable. But this is exactly what is happening today. And just like in 1982 when the DOJ declared AT&T a monopoly and broke them up, Federal government intervention is again required to protect the public commons of the Internet from powerful monopolistic companies like Cogent (and other Tier 1 ISPs) that are engaging in censorship.
Cogent has deliberately and maliciously interfered with my
online businesses
in relationships across the world. They would ‘blackhole’ connections to my network resources. Blackholing is a practice by which Cogent
maliciously informed
third-party networks that my
own network is unreachable, which would cause the connecting client to abort their connection attempt.
This is more aggressive than simply refusing to connect to my networks directly. It is one thing for Cogent to refuse to directly connect to another network. By blackholing connections,
they Cogent lied about the availability of an address; a deliberate and malicious effort to disconnect my service from much of the Internet. This sort of censorship is generally reserved for national security, such as to stop the spread of a computer virus. It is the digital equivalent of Google Maps saying that someone’s store is not at a real address and cannot be found, despite having actual knowledge of where it is
and that the store is open for business.
In extreme situations, Cogent would even
electronically announce the network infrastructure of other companies to
induce them to modify their routing for specific IP addresses
that my services ran on on which my services ran as a means to censor us. I believe these actions were in violation of the Computer Fraud and Abuse Act (18 U.S.C. § 1030), as they effectively seized and modified computer resources without authorization as a means to disable a US-legal website. This happened in the US, but also in Poland, showing that Cogent was dedicated to the world-wide blockade of my community. Also in Poland, Cogent pressured a very large data center owned by Equinix in Warsaw to evict my server, which they did.
Although these are their two most memorable instances of censorship, Cogent will–to this day–continuously block any instance of my website that they can, and I must painstakingly go out of my way to avoid
them their electronic censorship.
Any time I look for more companies to do business with, I must first determine if they have a relationship with Cogent, and I cannot do business with any business that itself relies on Cogent. Whenever I look for more companies to do business with, I must first determine if they have a relationship with Cogent, and I cannot engage with any company that relies on Cogent.
But I have never been a direct customer of Cogent. All of their censorship actions have been
directed against me
and my businesses through
their own Cogent itself, Cogent's customers, or the customers of their customers, or so on.
Edit: fixed a couple of typos, reload this post