FCC Restoring Internet Freedom Docket

Executive Summary

Emprata, LLC, a consulting firm specializing in advanced data analytics, accessed the full dataset of comments submitted to the Federal Communications Commission’s (FCC) “Restoring Internet Freedom” docket and performed a comprehensive, independent analysis of the comment data. At the time of our analysis, there were 21.766 million comments in the docket. Our findings are summarized herein.

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Forming Conclusions: The lack of user authentication by the Electronic Comments Filing System (ECFS) makes it difficult to determine “genuine” comment submissions. Emprata was also not able to authenticate the filer, address, email, or comment data used for this analysis, nor the methods used to collect those data elements. As a result, it is very difficult to draw any definitive conclusions from the comments found in the docket. Any conclusions that one might draw from the data would be based on the subset of data that they considered to be “real.”
All Comments: Considering all 21.766 million comments at face value, general sentiment is against repeal of Title II (60% against, 39% for). General sentiment favors repeal of Title II when eliminating duplicative comments and comments from email domains that appear to be illegitimate.
Form Letter Comments: The overwhelming majority of comments for and against repealing Title II are form letters (pre-generated portions of text) that appear multiple times in the docket. The form letters likely originated from numerous sources organized by groups that were for or against the repeal of Title II. Form letters comprise upwards of 89.8% of comments against Title II repeal and upwards of 99.6% of the comments for Title II repeal.
Unique Comments: There are significantly more unique comments submitted against Title II repeal
(1.77 million) versus for Title II repeal (24k). In addition, there are considerably more “personalized” comments (appearing only once in the docket) against repeal (1.52 million) versus 23k for repeal. Presumably, these comments originated from individuals that took the time to type a personalized comment. Although these comments represent less than 10% of the total, this is a notable difference.
Data Completeness: More than 81% of the total docket contained complete (i.e. usable) street address, city, state, ZIP code, and email information. 98% of comments in favor of the repeal of Title II contained usable data versus 70% of comments against the repeal of Title II. In addition, based on a 65% sampling of addresses, 84% of addresses for repeal of Title II were found to be valid versus 68% against repeal.
Artificial Email Domains: More than 7.75 million comments – the largest percentage of any set of comments (36% of the total comments) – appear to have been generated by self-described “temporary” and “disposable” email domains attributed to FakeMailGenerator.com and with nearly identical language. Virtually all of those comments oppose repealing Title II. Assuming that comments submitted from these email domains are illegitimate, sentiment favors repeal of Title II (61% for, 38% against).
International Comments: An unusually large volume of comments (1.72 million) are attributed to international addresses, which we did not verify. The vast majority of those comments (99.4%) oppose repealing Title II.
Duplicative Comments: 9.93 million comments were filed from submissions listing the same physical address and email, indicating that many entities filed multiple comments. This was more prevalent in comments against repeal of Title II (accounting for 82% of the total duplicates), with a majority of duplicate comments associated with email domains from FakeMailGenerator.com.

Entire Dataset

ALL – Considers all comments submitted to the FCC
DOMESTIC – Considers only domestic comments
INTERNATIONAL – Considers only international comments
EXCLUDE FAKEMAILGENERATOR
Excludes comments from 10 email domains associated with FakeMailGenerator.com

Entire Dataset Comment Count - Exclude FAKEMAILGENERATOR

Unique Comments

UNIQUE COMMENTS – Number of unique comments in the docket
TRULY UNIQUE COMMENTS – Number of comments appearing only once in the docket

Eliminating Duplicative Comments

ONE PER ADDRESS – Considers only the first comment for each unique address, city, state, ZIP code combination
ONE PER EMAIL – Considers only the first comment from each email address
ONE PER ADDRESS/EMAIL – Considers only the first comment from each unique address and email combination

Considering only Valid Addresses
(Considers sample address data through August 4, 2017)

VALID ADDRESS – Considers only comments where an exact address match was found
ONE PER VALID ADDRESS – Considers only the first comment from each valid address

Considering Only Valid Address - Comment Count

	AGAINST Title II Repeal	FOR Title II Repeal
Comment Summary
Total	13,090,150 (60.1%)	8,595,668 (39.5%)
Avg. Per Day	129,605	85,106
Unique Comments	1,769,811	24,348
Appear 1x	1,516,296	23,309
Top 7 Days
Top 3 Comments	» “I AM IN FAVOR OF STRONG NET NEUTRALITY UNDER TITLE II OF THE TELECOMMUNICATIONS ACT. SINCERELY, NAME” (7,569,190) » "THE FCCS OPEN INTERNET RULES NET NEUTRALITY RULES ARE EXTREMELY IMPORTANT TO ME. I URGE YOU TO PROTECT THEM. (...)" (445,658) » "I STRONGLY OPPOSE CHAIRMAN PAI’S PROPOSAL TO REVERSE NET NEUTRALITY PROTECTIONS BECAUSE A FREE AND OPEN INTERNET IS VITAL (...)” (340,205)	» (VARIATIONS OF) "DEAR FCC, I AM CONCERNED ABOUT NET NEUTRALITY. I STRONGLY URGE THE FCC TO REPEAL (...)” (1,384,893) » "IN 2015, CHAIRMAN TOM WHEELERS FEDERAL COMMUNICATIONS COMMISSION FCC IMPOSED RESTRICTIVE TITLE II, UTILITY-STYLE (...)" (1,083,324) » "BEFORE LEAVING OFFICE, THE OBAMA ADMINISTRATION RAMMED THROUGH A MASSIVE SCHEME THAT GAVE THE FEDERAL GOVERNMENT BROAD REGULATORY (...)" (1,047,049)
Email Domain Summary
Top 10 Domains (comment count – Sentiment %)
Geographic Summary
Address Match %	68%	84%
Top 5 States (comment count)	California (1,244,220) Texas (761,062) New York (702,899) Florida (558,356) Illinois (499,866)	Texas (826,653) California (730,606) Florida (582,724) New York (395,731) Georgia (383,770)
Top 5 States (%)	Wash DC (76.6%) Vermont (76.2%) Massachusetts (76.2%) Minnesota (68.2%) Washington (67.3%)	Alabama (62.9%) South Carolina (62.2%) Louisiana (58.8%) Georgia (56.6%) Mississippi (56.5%)
Top 5 Countries (comment count)	Russia (444,925) Germany (433,033) France (194,530) India (6,801) Canada (4,590)	Canada (34) Australia (29) Germany (21) United Kingdom (18) Spain (12)