Public Comments to the Federal Communications Commission About Net Neutrality Contain Many Inaccurac
Correction: This report initially noted that 450,000 comments were submitted to the FCC during its previous open comment period on net neutrality. That data point was based only on the initial comment period, spanning Feb. 9-July 18, 2014. The FCC subsequently reopened the comment period through Sept. 15, 2014, and the report now reflects the total number of comments received during the entirety of the 2014 public comment period. In addition, a reference to John Oliver in a sentence referring to the most popular pro-net-neutrality comment has been removed. Pew Research Center has issued a 
In theory, the process for submitting a comment to the FCC included a validation technique to ensure the email address submitted with each comment came from a legitimate account. The submission form clearly states that all information submitted, including names and addresses, would be publicly available via the 
In many instances, thousands of comments were submitted simultaneously – down to the second.
In the most prolific example, 475,482 comments were submitted on July 19 at precisely 2:57:15 p.m. EDT. Almost all of those comments were pro-net neutrality and offered variations of text that appeared on the site Some comments submitted to the FCC had nothing to do with net neutrality and appeared to be attempts by users to further complicate the data collection: Of course, the fact that many comments were submitted at precisely the same time does not mean the organization or webpage where the text first appeared was responsible for automating or standardizing those submissions. It is possible a third party used the text and submitted these comments on its own. Nor is there anything inherently wrong or sinister about bulk filing of comments. This analysis simply highlights the scale at which digital tools are being brought to bear in the long-standing practice of commenting on proposed government rules. During the four-month period in which the FCC accepted comments on net neutrality, an average of 172,246 posts were submitted per day. But the comment period featured several long stretches with few submissions, punctuated by bursts of intense activity. The comment period officially opened on April 27, and only 453 comments were submitted on that day. On Sunday, May 7, two major events occurred that coincided with a significant increase in submissions. That evening, comedian John Oliver broadcasted a nearly 20-minute segment on his HBO show Last Week Tonight defending net neutrality and encouraging his viewers to submit comments supporting his position. The last time the FCC considered net neutrality in 2014, a Pew Research Center analysis showed that John Oliver's program also led to a spike in the number of comments submitted. Also on May 7, the FCC issued a news release stating that a distributed denial of service attack (DDoS) occurred against the electronic filing system. Some critics have questioned whether an actual DDoS attack occurred, noting that the FCC did not provide documentation regarding the attack following a Freedom of Information Act request by the website Gizmodo. And two Democratic members of the House Energy and Commerce Committee have since requested an investigation into the matter. More than 2.1 million comments were submitted in the five days following those two events (May 8-12). Those comments made up 10% of all the comments submitted during the entire submission period. In response to this surge of submissions, the FCC released a public notice on May 11 that announced a “sunshine period” for the week spanning May 12-18 in which the FCC would temporarily stop taking public comments due to the large number of submissions. According to the FCC's statement: “This means that during this brief period of time, members of the public cannot make presentations to FCC employees who are working on the matter, and are likely to be involved in making a decision on it, if the underlying content of the communication concerns the outcome of the proceeding … The Commission adopted these rules to provide FCC decision-makers with a period of repose during which they can reflect on the upcoming items.” Although the FCC claimed it would not accept comments during this period, the Center's analysis finds that more than 93,000 posts submitted on those days were included among the final database made available for public review. The rate of comments slowed significantly over the next few weeks. From May 30 to July 8, the number of comments declined to an average of only 5,832 posts per day. In mid-July, activity increased dramatically and remained relatively high until the original date the comment period ended. The single day with the most submissions occurred on July 12. Online activists dubbed the day “Net Neutrality Day of Action” or “Day of Action to Save Net Neutrality” and numerous sites altered their websites to include statements favoring net neutrality. On that day alone, 1.4 million comments were submitted electronically to the FCC.
Off-topic comments
• At least 34 comments included references to Bee Movie, some of which contained portions of the movie's script.
• Fully 108 comments had more non-alphanumeric characters – such as equal signs (=) or ampersands (&) – than alphanumeric characters.
• Others consisted entirely of short messages without a clear meaning, such as: “get a hobby,” “Democracy,” “cat videos,” “google it,” “SAD!” and “!!!!!!!!!!!!!!!!!!!!!!!!!”The comment period was marked by bursts of intense activity and long stretches with few submissions
