Level 3 Communications Issues Statement Concerning Comcast's Actions

Justin M. Streiner streiner at cluebyfour.org
Mon Nov 29 21:11:50 CST 2010

On Mon, 29 Nov 2010, Leo Bicknell wrote:

> When you have users and no content how can the traffic be equal?
> When you have content and no users how can the traffic be equal?
> Ratio is horribly outdated.  Cable and DSL providers enforce out
> of ratio at the edge with technology and policy.  My cable modem
> is 8 down 2 up, yet my traffic profile is supposed to be equal?  I
> can't host any "servers" by my TOS, but aggregated up the ratio is
> supposed to be 1:1?
> No one will ever be in ratio compliance with an eyeball dominant
> network.  Ever.   Period.  It's not possible via technology and
> TOS.  Enforcing it as an eyeball network just forces content providers
> to aquire eyeballs, e.g. compete with you.  That's bad business.

Amen.  Ratios are an artifact of the '90s.

I am a service provider and I have lots of eyeballs on my network.  You 
are a content provider with content that many of my eyeballs want to 
access.  It makes sense to peer, so that traffic has the 'best' path 
between content and eyeballs, though there are many interpreations of 
'best' in this sense.

The argument that Netflix, Youtube, or any other bandwidth-heavy content 
provider is forcing eyeball providers to invest in infrastructure upgrades 
and not receiving any return on that investment is complete BS.  What is 
happening is that the tipping point of the stat-mux model that just about 
every service provider in the world lives and dies by is changing as a 
result of customers with fatter pipes now having uses for those pipes 
other than (or in addition to) P2P downloads.

The content provider either pays an upstream service provider to haul 
their bits toward their intended destination, or in the settlement-free 
model, they agree to hand off at a given point/points at a given maximum 
rate.  *Both* sides of that relationship have infrastructure and operating
costs related to supporting that settlement-free peering arrangement, and 
that applies whether the peering happens through private interconnects, 
or happens at an exchange point.  Comcast's assertion ignores that point, 
and essentially asks Netflix to pay twice for the same traffic, either 
directly or indirectly.

In the scenario above, I would expect to see lopsided traffic 
distribution as my eyeballs download/stream content from you.  Whether 
the bits flow from me to you or vice versa really doesn't change the costs 
associated with moving the bits.

AFAIC, Comcast really doesn't have a leg to stand on by doing this. 
Unfortunately L3 set a very bad precedent by caving into Comcast's 


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