Open Letter to Mark Zuckerberg Regarding Internet.org

Mark Zuckerberg; Facebook Founder and CEO
Mark Zuckerberg; Facebook Founder and CEO

We, the undersigned, share a common concern about the launch and expansion of Facebook’s Internet.org platform and its implications for the open internet around the world.

We support the goal of bringing affordable access to the two-thirds of the world who currently lack Internet access. Many of us have been working for years on initiatives to bridge the digital divide, such as building Internet access facilities in public libraries and telecentres, supporting local telecom ventures, making websites and services more accessible to people with feature-phones, and more. However, we have always sought to provide non-discriminatory access to the full open Internet, without privileging certain applications or services over others and without compromising the privacy and security of users.

These are key differences from Internet.org. In its present conception, Internet.org not only violates the principles of net neutrality, it also threatens freedom of expression, equality of opportunity, security, privacy, and innovation. In addition, it is our belief that Facebook is improperly defining net neutrality in public statements and building a walled-garden where the world’s poorest people can only access a limited set of insecure websites and services. Further, we are deeply concerned that Internet.org has been misleadingly marketed as providing access to the full Internet, when in fact it ,::only provides access to a limited number of Internet-connected services that are approved by Facebook and local ISPs.

In a May 4 video, Facebook CEO Mark Zuckerberg announced new rules pertaining to Internet.org and argued that net neutrality and Internet.org are not in conflict. However, on the accompanying website, the new rules explicitly state that “websites must be properly integrated with Internet.org to allow zero rating.”

Below we articulate our concerns about the current structure and implementation of Internet.org:

Net neutrality: Net neutrality supports freedom of expression by enabling people to seek, receive, and impart information. It requires that the internet be maintained as an open platform on which network providers treat all content, applications, and services equally, without discrimination. An important aspect of net neutrality states that everyone should be able to innovate without permission from anyone or any entity.

We urge Facebook to assert its support for a true definition of net neutrality in which ALL applications and services are treated equally and without discrimination — especially in the developing world, where the next three billion Internet users are coming online — and to address the significant privacy and security flaws inherent in the current iteration of Internet.org.

Zero rating: Zero rating is the practice by service providers of offering a specific set of services or applications that are free to use without a data plan, or that do not count against existing data caps. This practice is inherently discriminatory — which is why it has been banned in countries such as Canada, the Netherlands, Slovenia and Chile.

Zero rating is currently Internet.org’s basic model: Facebook is partnering with ISPs around the world to offer access to certain applications to users at no cost. These agreements endanger freedom of expression by letting service providers decide which services will be privileged over others, thus interfering with the free flow of information over networks.

Nomenclature: Internet.org misleadingly labels these zero-rated applications the “Internet,” when in fact the applications only offer access to a tiny portion of it. The project acts as a “walled garden” in which some services are favored over others — again, a violation of net neutrality.

Freedom of expression: The project raises other freedom of expression risks. The censorship capability of Internet gateways is well established – governments require ISPs to block access to sites or services. Facebook appears to be putting itself in a similar position, where governments could pressure the company to block certain content, or even, if users must log in for access, block individual users. The company should not take on this added responsibility and risk by creating a single centralized chokepoint for the free flow of information.

Privacy: We are also deeply concerned about the privacy implications of Internet.org. Facebook’s privacy policy does not provide adequate protections for new Internet users, some of whom may not understand how their data will be used and therefore may not be able to provide informed consent about its treatment. Facebook’s privacy policy does not provide adequate protections for new users to the internet. Given the lack of statements to the contrary, it is likely Internet.org collects data by its users when they utilize the apps and services that are part of the program, and there is a lack of transparency about how that data is used by Internet.org and its telco partners. Internet.org also concentrates internet usage in a handful of applications and services, making it easier for governments and malicious actors to surveil user traffic.

Security: The current implementation of Internet.org threatens the security of users and of the Internet as a whole. The May 4 update to the program prohibits the use of TLS (Transport Layer Security), Secure Socket Layer (SSL), or HTTPS encryption by participating services. This inherently puts users at risk, because their web traffic will be vulnerable to malicious attacks and government eavesdropping.

Two-tiered Internet: The economic boon that the Internet created in developed countries needs to be shared equally with the next three billion people, not stifled by Facebook’s new two-tiered Internet. Internet.org’s model — giving users a taste of connectivity before prompting them to purchase pricey data plans — fails to acknowledge the economic reality for millions of people who can’t afford those plans. These new users could get stuck on a separate and unequal path to Internet connectivity, which will serve to widen — not narrow — the digital divide.

Facebook should strongly support and advocate for safeguarding the principle of net neutrality, privacy, security, and other user rights in its discussions with national governments and regulators, while also applying these standards to its business initiatives.

Signed,

———–
Comments

Suggest changing “This practice is inherently discriminatory” to “The kind of zero rating practised by Internet.org is unfairly discriminatory”.

We would delete “fundamental” from “fundamental principles of net neutrality”, because this suggests a parity with fundamental human rights that we do not support. We would also delete “‘positive discrimination’, which covers” as this is too broad. We would also delete “An important aspect of Net Neutrality states that everyone should be able to innovate without permission from anyone or any entity.” This is not part of the net neutrality definition as we understand it. Also we would change “internet” to “Internet” throughout.

Any chance that this can also address the “poor internet for poor people” framing that leaders in India and elsewhere are lifting? It’s not just the privacy, zero-rating and NN aspects that are troubling. It’s the walled garden and the creation of a customer base without any push that access to the internet is a human right. http://qz.com/385821/poor-internet-for-poor-people-why-facebooks-internet-org-amounts-to-economic-racism/

– Tried to address all this.

The “are writing an open letter” wording is a bit redundant. Better – share a common concern about the launch…

-Addressed this

“which states that everyone should be able to innovate without permission” also appears to be redundant.

– fixed

Suggest: replace “telecos” with either telecoms operators or internet access providers

– replaced with “service providers” and “ISPs”

Do not create should be “do not treat” – the US-centric reference does not add meaning.

– fixed

” access to applications to users at no cost” – access to certain applications at no additional cost.

– fixed

Mark Zuckerberg announced –>Mark Zuckerberg claimed

– In this case, he did announce them I don’t see how “claimed” is more precise Hi Josh, to my understanding of the words, one generally “announces” something firm, but “claim” something more shaky. “Claim” in my mind, implies less credence from our side. This isn’t a huge deal for me, however.

about how that data is used by Internet.org and its telco partners – particularly bearing in mind the data-driven business model of Facebook.

I don’t understand the “potentially” before “government evesdropping” – surely the lack of security means that the are vulnerable?

– Fixed

– This is highlighting the dangers of lack of security, rather than a certainty of what’s taking place But surely malicious attacks aren’t a certainty either? In both cases, the weakened security creates a risk, potentially creating problems. Indeed, there’s a possibility that the dragnet approach of some governments makes this type of intrusion even more likely.

The “ask” needs a bit of refinement. Zuckerberg says he’s supporting net neutrality and we’re saying “please support net neutrality”. Maybe… We urge Facebook to assert its support for an internet that respects the principle of innovation without permission and that treats all applications and services without discrimination imposed either in the network or through billing practices… (or something in this direction)

– added something

First paragraph: “to a limited number internet-connected services” => to a limited number OF internet-connected services

– fixed

The definition of zero rating needs some clarification. For instance, some telcos are offering a free data allowance each day (completely unrestricted) in exchange for viewing an ad. This is zero rated data, but its not limited to a certain set of services. Other proposed solutions to the connectivity challenge include giving users a basic monthly data allowance to use on any site they like, funded by a USF. So IMHO the problem’s not really zero rated data. The problem is zero rated data limited to a walled garden or only available via a certain telco – which brings all the risks of privacy, market abuse etc we all care about.

– [This is Josh] I believe the definition of ZR included in the letter is commonly accepted so I’d prefer to leave it.

-I’d put the nut graph up front to make it a bit less theoretical:
“…is improperly defining Net Neutrality in public statements and is attempting to create a privately controlled walled garden where the world’s poorest people can only access Facebook partners.”
– made an edit

Also, could mention that our concern for the development of the next 3 billion is more genuine than his:
“The economic boom that the Internet created in developed countries needs to be shared equally with the next 3 billion people, not stifled by Facebook’s new two tiered Internet.”

– Added a new section on this.

I’d also delete “modus operandi”, as we should be wary that Zuck is painting us as elitists.

– tried to address this

Please bring up the fact that if Myspace or Friendster had set up something like Internet.org first, then Facebook would never have had a chance. If they had tried to reach these mobile customers through MyFriendInternet.org then all their user data would have been gobbled up by one of these older incumbents, only to be used against them anti-competitively. It’s a clear example of hom.
+1, what about the angle that it is not actually free access, but being paid for by the surrendering of private data?

Some minor issues, notwithstanding further comments:
* “Net Neutrality” is not God Almighty or Jack the Ripper, and shouldn’t be capitalized 😉
– done

* “(…)prohibiting “positive discrimination,” which covers price differentiation schemes like zero rating.” ZR is not
‘positive discrimination’, at least in the sense it is generally used in the political and human rights contexts. PD
means giving to a certain part of the population access to something that a more powerful or wealthier part has, with
less requirements or at a lesser cost. Typical PD examples are laws enacted by many countries reserving a certain
percentage of seats in the elective governmental bodies to women, ethnical minorities, etc. ZR would be, by the way
of example, passing an act to guarantee that a 40% of the MPs are women, but they are only allowed to vote certain
laws and not others. ZR is plain simple “price discrimination” aimed to create a captive clientele.
More comments later, as time permits. [~~EC]

ON LINE 27. ADD (between the lines): “We are also deeply concerned about the privacy implications of Internet.org. Facebook’s privacy policy does not provide adequate protections for new users to the internet, –who may not understand how their data is going to be used and therefore may not have enough information as a basis for consent for its treatment–!

I would rework this paragraph a bit:

In a video released on May 4, Facebook CEO Mark Zuckerberg announced the new rules pertaining to internet.org. He disputed that net neutrality and internet.org would not be in conflict. However, on the accompanying website, the new rules explicitly state that “websites must be properly integrated with internet.orgto allow zero rating.”

Changed the wording a bit:
We supportthe goal of bringing affordable access to the two-thirds of the world who are currently unable to access the internet. For years we have been working on initiatives to bridge the digital divide. Even with all our attempts we have always soughtto provide non-discriminatory access to the full open internet, without privileging certain applications or services over others and without compromising theprivacy and security of users.

These are amongst the key differences from the internet.org platform. In its current formation,the internet.org platform not only violates the principles of net neutrality,it also threatens freedom of expression, equality of opportunity, security,privacy, and innovation. We believe that Facebook is improperly defining netneutrality in public statements and building a walled-garden where the world’spoorest people can only access a limited set of insecure websites and services.

I’m not too sure about this bit, perhaps it could be reworked?
Furthermore,we are deeply concerned that this platform has been misleadingly marketed asproviding access to the full internet, when in fact it only provides access to a limited number of internet-connected services that are approved by Facebookand local ISPs.

A question of clarity: why are we writing internet with a capital letter?
Is it necessary to name internet.org throughout the letter? Can we not just refer to it as the platform etc.?

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About Elvis Mang'unyi 74 Articles
A Web & Mobile Apps Developer, Data cruncher, Infographics maker, Social media integration, Tech writer & Unashamedly Catholic!