Read the Report
SPL published the Preliminary TiPC Report December 14, 2017
What's the Issue?
Startup Policy Lab (SPL) is following up on reports that individuals’ identities have been appropriated without their consent or knowledge to submit comments to FCC Proceeding 17-108 regarding net neutrality between April 27th, 2017 and August 30th, 2017. The goal of our research is to evaluate the veracity of the public comments submitted by individuals and to lay a foundation for additional research on the topic of ensuring public comments.
Link to our 12/11/17 Media Alert:
Read about the TiPC Project in the news
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TechDirt: Two Separate Studies Show That The Vast Majority Of People Who Said They Support Ajit Pai's Plan... Were Fake
What is the TiPC Project?
The Truth in Public Comments (TiPC) Project is analyzing public comments submitted in response to the proposed repeal of Net Neutrality by the Federal Communications Commission (FCC). Our goal is to use data science, big data analysis, and on-the-ground journalism to separate authentic public submissions from fake comment campaigns. Our findings and data will be made public before the final December 14th FCC vote on Net Neutrality repeal. The purpose of this research project is to expose the abuse of public comment systems, to fight PR hacking campaigns that manipulate public opinion, and to ensure public confidence in the regulatory process.
Why does this project matter?
Similar to the well documented attacks waged through social media in the months preceding the 2016 election, malicious actors have again leveraged technology to stifle democratic outcomes. This time, however, the target of deception is government itself, and the breach is evidenced on government held servers. Democratic processes are never easy, but it is critical that citizens have trust and confidence in the democratic process.
The bogus comments to the FCC represent an evolution in organized cyber-aggression that employs an understanding of how information flows through government. SPL has concerns that the FCC is a canary in the coal mine for how malicious actors might try to undermine that trust and confidence. Democratic institutions must be prepared to combat this threat to ensure a vibrant, healthy, and accessible democracy for all.
Several observations of readily available data point to malicious activity:
Timestamps indicating bot driven batch loading of comments
Comments originating from duplicate, fake, and otherwise illegitimate email addresses, including submissions from known fake email generators
Comments originating from nations hostile to democratic values
Who is working on TiPC?
SPL is an independent think tank focused on providing research to inform data-driven policymaking. SPL has not taken a position on the issue of net neutrality.
No direct financial support was received in support of this project. Indirect support was received via pro bono legal support from Fenwick & West to ensure compliance with applicable and best practices regarding privacy laws and pertinent privacy policies and in-kind technical support was provided by QuestionPro to publish and collect survey data.
Please see our FAQs (click here) if you have additional questions or are looking for more details. Thank you.
Project Lead and Report co-author: Charles Belle
Data Scientist and Report co-author: Jeffery Kao
Researcher/Data Analyst: Sarah Rigdon
Communications: Gina Cooper
Paul Burkhard, Senior Data Scientist, Metis
Joseph Eddy, Senior Data Scientist, Metis
Andrew Blevins, Senior Data Scientist, Metis
Others we’d like to thank
In-kind and pro bono support provided by
What's next for the TiPC Project?
Our goal is to launch a more robust study that includes other agencies. This work would provide government agencies (Federal, State, and local) with evidence to inform practices and tools to keep the public comment open, transparent, accessible, and secure.
If you want to support independent research to keep our democratic processes open, transparent, accessible, and secure, please support this project!