Comments of the Association for Competitive Technology

The Association for Competitive Technology hereby submits these comments in response to the Commission’s Notice of Proposed Rulemaking (NPRM), GN Docket No. 09-191 and WC Docket No. 07-52.nWe agree with much of what the Commission proposes in the NPRM. Developers of software and providers of IT services rely on competition and unrestricted user access to content, applications, and devices. These principles have effectively served Internet communications policy for the past six years, since they were first articulated by the Commission.

ACT fully supports the four principles and believes they represent pro-consumer, and pro-innovator policies. The NPRM proposes to formally adopt the original four principles, and at the same time add two new rules on nondiscrimination and transparency. These new additions are well intentioned but their adoption may unintentionally harm the ability of developers to create new applications and IT services that use wireline and wireless Internet communications.