Tony, Thanks for your comments. I'm grateful that you've posted them, because they signal to me that I'm on the right track. As you know, I have enormous respect for you and for VeriSign. And you are a world-class expert in this area, which is why I invited you to speak at Bellhead/Nethead. I'm sorry you can't be there. It's clear you'd have a great deal to contribute. FCC has said ip-enabled services (which it defines as everything -- every web page, every server, every application -- everything that uses IP -- see n.1 of the NPRM -- "all services and applications relying on the Internet Protocol family") aren't necessarily appropriately characterizable as telecommunications services. That means, as you say, that they're not subject to "common carrier" regulations. I called that set of regulations "economic" regulations, and that's a term that FCC uses frequently. So we agree on this point. Where we diverge is that you go on to say "What they said is that they don't want to apply common carrier regulation to IP-enabled services. As an alternative, they are considering tailored mandates applicable to defined classes of services." You see "tailored mandates" -- I see very broad suggested rules. Rules about disability access, about "consumer protection" (as yet undefined), about E911 services, about contributions to Universal Service funds, and, yes, about CALEA. You say the FCC has been making rules about these things for 30 years. They have been doing so for telephones. They have not been doing so for email, IM, web pages, and p2p services. They don't have jurisdiction to do so, in my view. Their ancillary jurisdiction doesn't stretch that far. At n.155, FCC suggests that it has authority to "tariff" online newspapers. They may just be feeling lighthearted, but this is an indication of just how far the agency believes its jurisdiction extends. FCC certainly has exclusive jurisdiction, and should preempt state rules -- but that doesn't mean it can impose "social policies" itself on ip-enabled services. Section 230, as you know, points in exactly the opposite direction. So. We're operating from the same set of facts. This filing was made by you on behalf of VeriSign, as was this one in the ip-enabled services rulemaking. You see these as targeted mandates that are focused on a particular class of services. I see them as a very broad set of proposed rules, for a potentially unlimited set of services and applications, that may implicate areas that are far beyond the FCC's jurisdiction. We're really not that far apart -- on the facts, at least. We just see the facts differently. I do see CALEA as a design mandate request from the FBI. I'm grateful for the pointers to the other two rulemaking proceedings, and I'll follow them with interest. I don't agree with you on spam -- the market is solving that problem without national telecom agencies getting involved. If you use SpamAssassin or other useful tools (or adopt the accountable net approach), you won't get spam. Indeed, the FTC has decided not to create a "do not spam" list because it's just too hard. So. Please don't take this personally, as I didn't take your posting here. But I disagree with you. Susan