Comments of Lincoln Network on Bridging the Digital Divide for Low-Income Consumers

The D.C. Circuit largely upheld the FCC’s 2018 Restoring Internet Freedom Order (“2018 RIF Order”) in Mozilla v. F.C.C., but the Court requested that the FCC seek comment on three aspects of its 2018 RIF Order (i.e, public safety, pole attachments, and Lifeline). After careful review of the docket, Lincoln Network remains convinced that the 2018 RIF Order is necessary to promote the stated policy objectives listed in the Notice and agrees with the commission that consumers are better protected by the Federal Trade Commission (“FTC”) on issues related to net neutrality more generally. This is because the issue of net neutrality is only appropriately analyzed through the lenses of competition and consumer protection, which is primarily for the FTC to resolve. The 2018 RIF Order’s light-touch regulatory approach allows the industry to innovate and the FTC to perform its duty to protect competition and consumers consistent with “net neutrality” principles in the broadband Internet access service (“BIAS”) market.

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