Now you know I'm an oldie!
Two years ago I think I heard that at every Boys Game I was at. This last year I didn't hear it a single time.
Yea it is but I never hear it often at any games.
yea its kinda old idk maybe it got overplayed in certain places, but I guess alot of songs are old so that shouldnt be a reason why they dont play it much.
Yea most of the good warm-up songs are old.
ya that one is a good one i guess ive never really heard it overplayed. I know they played it in Dickinson quite a bit for regionals but ya definatly good.
Thats a good one frog. I'll take that one and Enter Sandman. Those 2 get me goin!


Houlagan Lacrosse Select Travel Team is a year long program. We build our teams in the fall so that we have a cohesive, competitive team to bring to the summer tournaments. We respect and encourage our players' decisions to continue in other sports. We do our best to be flexible when it comes to sport conflicts. However, a strong team can only be built with practice, camaraderie and commitment. This is why we encourage our teams to play and practice together throughout the entire year.
Focus on team-building/bonding, skill development, and game strategy and concepts, and having a blast at the fall tournaments.
We encourage our players to participate in as many winter programs as possible.
Focus on putting all the pieces together and competing at the highest level we can throughout the summer tournament schedule.


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Blog Featured Clients
Featured Client: Robbie White
We are very grateful for each and every client, and hope our blog can help market their causes while also demonstrating the wide variety of people who choose PrintKEG. Welcome to our new series, Featured Clients.
Robbie White was born in Charlotte, N.C. in 1948, the second son in a family of five boys. His father was a music teacher in the Charlotte Mecklenburg schools, and his mother was an elementary school teacher. At the early age of two he contracted encephalitis, after which he had to learn to walk again. At the age of three he was diagnosed with polio and hospitalized for six months. The illness left him paralyzed in his right arm, and he once again had to learn to walk. Despite his handicap, he graduated from UNC at Charlotte with a BA in Psychology and an Elementary Teaching certificate. In 1972 he was hired as a remedial reading and math teacher at Fennell Elementary School, located in Yemassee, S.C. Robbie White has been teaching at the same school now for 38 years.
In the early 80's, he developed a keen interest in the new personal computers. He acquired the first classroom computer in Hampton District 1 in 1982. Robbie formed the first computer lab for Fennell Elementary School in 1990 and has been the technology teacher ever since.
In 1989 Robbie White wrote the first grant awarded to Fennell Elementary. Over the next 18 years, Robbie wrote and was awarded 13 more grants totaling $270,000 for Fennell math, science, reading and technology programs. In addition, starting in 2001, Robbie participated in a team of teachers that received well over a million dollars for Fennell reading and after-school programs.
From 1978 to 1982 Robbie drew and painted the illustrations with watercolor for two children's books that have been in a drawer for 30 years. In 2007 he pulled them out and began working on them again. It took three years for him to finish the books and prepare them for print. Then in 2010, thanks to PrintKEG.com (where his son Nathaniel is Production Manager), he was finally able to realize his dream of self-publication. The first book, "The Pretty Moon", is an old English lullaby that was handed down for generations in his family. The second book, "The Good Shepherd", is the 23rd Psalm illustrated with pictures of children.
Since September 2010, Robbie has distributed 300 books and has recently ordered 500 more of the high quality, full color books from PrintKEG in December. Robbie developed an application based on "The Pretty Moon" that runs on the iPhone, iPod Touch and iPad. The program was accepted to the App Store by Apple in June 2009 and has sold in ten countries. The Pretty Moon App includes the option of listening to Robbie's mother sing the lullaby or the option of turning the pages with a swipe of the finger. Next Robbie wants to develop a Good Shepherd App and start illustrating a new children's book. If you would like more information and a preview, visit Robbie White's website or email him at robbaby60@gmail.com.
We would love to learn about you! Learn more About our Featured Client series.
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May has gone by so fast, I am looking forward to summer. The kids have 3 weeks left of school so I can't sit back and relax just yet.
The cloud Roads and Demon King look fantastic! I hope you enjoy them, going to check them out myself.
Have a wonderful week, Jennifer! Happy Reading!
I hope the next 3 weeks go by smoothly for your family. :) Happy reading!
I love that King just keeps putting out awesome books. I've heard good things about this one. I look forward to your thoughts.
I don't know how on earth he does what he does. I'm hoping to finish The Outsider tonight.
I'm glad you are enjoying The Outsider. I'm waiting until Stormi gets a library copy so we can make it our buddy read. It's cool you got to meet some great authors and it looks like you grabbed some good books. I LOVE Seanan McGuire. I hope you love Every Heart a Doorway as much as I did. The second one was my fave and the third fell short for me (too much like Alice in Wonderland) but I'm hopeful about the next one.
I am listening to the Outsider narrated by Will Patton and loving it. Glad to hear you are enjoying it too. Yay to the lazy days of summer. Enjoy!
Nice! I'm in the middle of Finders Keepers as well, and Will Patton seems to be a good narrator.
I definitely want to get the new Stephen King, I love his writing, and The Road to the Dark Tower looks interesting, am checking that out. When I read horror, I prefer Mr. King!! He is my favorite.
I hope you are able to get a copy of The Outsiders. It is worth a read!
I do so love summer. Looks like you have some great summer reading ahead. Enjoy your books and have a great week!
I do have some great reads lined up. :) This has been a good reading year overall.
Comicpalooza sounds like it was a lot of fun. And you got to meet James Marsters! How awesome is that?! I hope you enjoy all your new books. The Wells and McGuire books are ones I would like to read at some point. Have a great week!
It was really great getting to meet James Marsters. :) Thanks!
Comicpalooza sounds awesome. I'd love to meet Martha Wells after reading the first two Murderbots. Curious about the Cloud Roads too.
Yay for summer! It was nice being able to congratulate Martha Wells on her Nebula win for All Systems Red.
I really want to read some Brain Keene it's been years! Have a great week!
With the exception of Pressure, it had been a long time since I had read Keene, too. The Conquerer Worms was a fun choice.
I also watched James Marsters panel, and it was my favorite of the convention. I was so happy the audience was just as big of fans of the Dresden books as they were of Buffy! It was so great.
I'm so looking forward to The Outsider! Unlike King's other books in recent years, which have been mixed with critics, this one seems to be garnering near universal praise and positive reviews.
Wow! Lots of great books you have here! Glad you got to meet James Marsters! I would like to meet him someday!
It sounds like you had a great time at the event. I hope you enjoy Every Heart a Doorway by Seanan McGuire - I've read this title (& enjoyed), although not yet progressed with the series.
Happy reading & a lovely week to you!
Thanks, Jade! I'm looking forward to seeing what the McGuire series is all about. I'm expecting something quite unique/strange.
It is definitely worth the read! You managed Sleeping Beauties, you can't put off The Outsider. LOL.
School is out here too and I'm loving it for the most part! I really love the non-alarm clock part especially. I really need to read more Stephen King. I listened to A Good Marriage at the beginning of the year and it seriously creeped me out but I haven't tried any others. Have a great week!
Comicpalooza sounds great. I follow Seanan McGuire on Twitter and would love to get a chance to meet her. Come see my week here. Happy reading!
Isn't it great to have a fav author like Stephen King for you, and the book is out and you are into it.
I really want to read the Seanan McGuire series. And definitely the King book!! I am so excited for Wyatt to be done with preschool for the year. I am ready to just enjoy summer days with him. I have missed him! Lol.
Enjoy your week and summer time happenings!
SPIKE! That's awesome! I love James Marsters. I'm jealous.
Comicpalooza sounds fun. You got The Outsider! I'm envious. I need to get that one. I had mixed feelings about the Dark Tower books. Some of them are amazing, and some of them are really bad. Have a great week. Enjoy your new books!
So jealous of your Comicpalooza visit! We're having a book event in October and I'm hoping to go. I haven't been to one of these gatherings since the late 90's and it scares me more than a little bit. All those people . . . And you met Spike! That must've been a highlight, for sure.
Comicpalooza sounds fun, glad you enjoyed it! I hope you enjoy your new reads and that you had a great week!
Haven't read any of these yet, but The Dark Tower series is on my list :) enjoy!


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Q: Forms - Cycling Through Records I have a MS Access 2010 database with two tables; one for Contracts and the other for Projects. Relation is 1 Contract to many projects. I have a MainForm (Single) that pulls up the contract with a subform that shows related projects (located in Detail section of MainForm) . I WAS able to search through each record of the MainForm using the record navigator at the bottom. As the Contract record changed on the MainForm the subForm was populated with the projects for next Contract record. Estimated number of records (Contracts) was about 65
Today I added two new fields both in the Contracts table and Projects table to capture the date last modified (LastModDate & LastModTime). Everthing is populating as expected except now the search record bar for the MainForm is showing 227 records which is the total number of project records. The search bar for the the SubForm displays the number of projects for that Contract record.
Looking for advice on pulling the search next record back to the contract level versus the project level.

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A young boy searches a future world wasteland for a rumored cure for his dying mother.
Director: Bruce Thierry Cheung, James Franco
Cast: Ben Youcef, James Franco, Jeffrey Wahlberg, Lucy Liu, Margarita Levieva
The Sound & the Fury
A look at the trials and tribulations of The Compson siblings, living in the deep south during the early part of the 20th century.
Director: James Franco
Cast: Ahna O'Reilly, Danny McBride, Jacob Loeb, James Franco, Joey King
Based on the 1930 classic by Faulkner, it is the story of the death of Addie Bundren and her family's quest to honor her wish to be buried in the nearby town of Jefferson.
Director: Dustin Bricker, James Franco
Cast: Ahna O'Reilly, Beth Grant, Brady Permenter, Danny McBride, James Franco
In 19th century Baltimore, Isabel Porter, a girl stricken with grief from her parents' untimely death, voluntarily checks herself into the Rosewood Institute. Subjected to bizarre and increasingly violent pseudo-scientific experiments in personality modification, brainwashing and mind control, she must...
Director: James Franco, Pamela Romanowsky
Cast: Amber Coney, Beth Grant, Cynthia Murell, Eric Roberts, James Franco
In Dubious Battle
In the California apple country, nine hundred migratory workers rise up "in dubious battle" against the landowners. The group takes on a life of its own-stronger than its individual members and more frightening. Led by the doomed Jim Nolan, the...
Director: James Franco, Janet Beeson, Robin Meyers
Cast: Bryan Cranston, Ed Harris, James Franco, Josh Hutcherson, Nat Wolff
Genre: Comedy, Drama, History
Cast: Alison Brie, Ari Graynor, Dave Franco, Hannibal Buress, Jacki Weaver
20167h 12m1,111 views
An English teacher travels back in time to prevent the Kennedy assassination, but discovers he is attached to the life he has made in a bygone era.
Director: Fred Toye, James Franco, James Kent, James Strong, John David Coles, Kevin Macdonald
Cast: Annette O'Toole, Cherry Jones, Chris Cooper, Daniel Webber, George MacKay


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February 12 Quick Kicks Podcast
2016 NFL Draft Detroit Lions Football Podcast NFL Seattle Seahawks
ITP Editors
With the Super Bowl now fading into our rearview mirror, the February 12 Quick Kicks Podcast begins to tackle the offseason with a look at some of the key issues that are in play for teams as we had towards free agency. Chuck Zodda and Mark Schofield delve into the sudden retirements of Calvin Johnson and Marshawn Lynch and how these moves may send ripples throughout the NFL in the offseason. Topics include:
Whether potential early retirements have to be something for NFL teams to prepare for after the moves from these two superstars and other players in recent years such as the San Francisco 49ers' Chris Borland last offseason (2:48)
Other early retirements in the history of the NFL including Jim Brown, Barry Sanders, and Ricky Williams, and whether NFL teams need to do additional due diligence in figuring out the place football has in a player's life (5:22)
Which of these two teams will have the bigger challenge replacing Lynch and Johnson, and whether the roles in which these players were currently used will make it easier for their teams to find capable replacements (10:50)
Our Twitter Question of the Day, "Who are the candidates to run the fastest at the combine this year?" (14:20)
If you are having trouble with the embedded player, listen on our SoundCloud page.
Subscribe to ITP: The Podcast on our iTunes page.
Follow us on Twitter @ITPylon.
Draft Spotlight: Tyler Ervin, RB
The Hidden Game of Super Bowl 50


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G. Koelsch
Highly Influential Citations159
J. Tang
A. Ghosh
D. Selkoe
649 Publications, 135,938 Citations
C. Haass
Human aspartic protease memapsin 2 cleaves the beta-secretase site of beta-amyloid precursor protein.
X. Lin, G. Koelsch, S. Wu, D. Downs, A. Dashti, J. Tang
The cDNAs of two new human membrane-associated aspartic proteases, memapsin 1 and memapsin 2, have been cloned and sequenced. The deduced amino acid sequences show that each contains the typical pre,… Expand
Structure of the protease domain of memapsin 2 (beta-secretase) complexed with inhibitor.
L. Hong, G. Koelsch, +5 authors J. Tang
Memapsin 2 (beta-secretase) is a membrane-associated aspartic protease involved in the production of beta-amyloid peptide in Alzheimer's disease and is a major target for drug design. We determined… Expand
Genome scan of human systemic lupus erythematosus: evidence for linkage on chromosome 1q in African-American pedigrees.
K. Moser, B. Neas, +20 authors J. Harley
Systemic lupus erythematosus (SLE) is an autoimmune disorder characterized by production of autoantibodies against intracellular antigens including DNA, ribosomal P, Ro (SS-A), La (SS-B), and the… Expand
Subsite Specificity of Memapsin 2 (β-Secretase): Implications for Inhibitor Design†
R. T. Turner, G. Koelsch, +4 authors J. Tang
Memapsin 2 is the protease known as β-secretase whose action on β-amyloid precursor protein leads to the production of the β-amyloid (Aβ) peptide. Since the accumulation of Aβ in the brain is a key… Expand
β‐Secretase inhibitor GRL‐8234 rescues age‐related cognitive decline in APP transgenic mice
W. Chang, Xiangping Huang, +5 authors J. Tang
Medicine, Biology
FASEB journal : official publication of the…
Alzheimer disease is intimately linked to an excess amount of amyloid‐β (Aβ) in the brain. Thus, therapeutic inhibition of Aβ production is an attractive clinical approach to treat this disease. Here… Expand
Human aspartic protease memapsin 2 cleaves the b-secretase site of b-amyloid precursor protein
Xinli Lin, G. Koelsch, S. Wu, D. Downs, A. Dashti, J. Tang
Biochemical and structural characterization of the interaction of memapsin 2 (beta-secretase) cytosolic domain with the VHS domain of GGA proteins.
Xiangyuan He, G. Zhu, G. Koelsch, K. Rodgers, X. Zhang, J. Tang
Memapsin 2 (beta-secretase) is a membrane-associated aspartic protease that initiates the hydrolysis of beta-amyloid precursor protein (APP) leading to the production of amyloid-beta and the onset of… Expand
Enzymic characteristics of secreted aspartic proteases of Candida albicans.
G. Koelsch, J. Tang, +4 authors X. Lin
Biochimica et biophysica acta
Candida yeasts are rarely infectious, but frequently cause life-threatening systemic infections in patients immunocompromised by AIDS or by immunosuppressive therapeutics. The secreted aspartic… Expand
Crystal Structure of Memapsin 2 (β-Secretase) in Complex with an Inhibitor OM00-3†
L. Hong, R. T. Turner, G. Koelsch, Dongoo Shin, A. Ghosh, J. Tang
The structure of the catalytic domain of human memapsin 2 bound to an inhibitor OM00-3 (Glu-Leu-Asp-Leu*Ala-Val-Glu-Phe, Ki = 0.3 nM, the asterisk denotes the hydroxyethylene transition-state… Expand
Memapsin 2 (β‐secretase) cytosolic domain binds to the VHS domains of GGA1 and GGA2: implications on the endocytosis mechanism of memapsin 2
Xiangyuan He, W. Chang, G. Koelsch, J. Tang
Memapsin 2, or β‐secretase, is a membrane‐anchored aspartic protease that initiates the cleavage of β‐amyloid precursor protein (APP) leading to the production of β‐amyloid peptide in the brain and… Expand


text:
HERE'S LOOKING AT YOU: Notts County
We take a closer look at this weekend's opponents
@officialcufc
The Blues are on home soil again this weekend as high-flying Notts County visit Cumbria in Sky Bet League Two.
This weekend we welcome Match Sponsors Thomas Graham to Brunton Park.
They are regular and valued sponsors of the club and are hosting their guests in Foxy's Restaurant. Kelso Parts / Lloyd Group are our Associate Sponsors and Donleys are our Match Ball Sponsors.
After late heartbreak against Wycombe in midweek, United will be hoping to go one better and seal three points against the Magpies.
Kevin Nolan's side, meanwhile, will be looking for a response from a disappointing defeat to Crewe last time out as they seek to stay in contention at the top of the table.
We put Wycombe under the spotlight ahead of their visit to Brunton Park:
Have a flutter on the game with our official betting partner, Sky Bet:
Sky Bet tip: Exactly one goal to be scored can be taken at 4/1.
Exactly one goal has been scored in four of Carlisle's last five outings.
Click HERE for full details and more betting markets - please bet responsibly.
The Magpies were battling against relegation for large parts of the last season, until the appointment of Nolan saw them climb away from the drop zone towards the end of the season.
And Nolan has continued his fine work this campaign, with Notts currently sitting second in League Two after a terrific start to the season which has seen them win nine of their opening 14 games.
Notts have lost only three league games all season, although two of those have come in their last six outings as both Crewe and Mansfield got the better of Nolan's men.
They certainly seem to have all the credentials to be title contenders this year, and will be keen to pick up three points on the road this weekend to keep them in the thick of it in the automatic promotion places.
Common Connections
There's plenty of links between the two clubs, with no fewer than four former Carlisle players currently plying their trade at Meadow Lane.
Goalkeeper Adam Collin spent four years at Brunton Park while defender Shaun Brisley moved to Nottinghamshire this summer after spending just a year in Cumbria.
Meanwhile centre back Mike Edwards is still registered as a player, although his main role now is at Notts' strength and conditioning coach.
Popular midfielder Liam Noble has also made the move to Notts, although he will be unable to play for the club until January after his contract at Forest Green was terminated.
Meanwhile in the Carlisle camp, Gary Liddle spent time at Meadow Lane under the lead-ership of Keith Curle, who was in charge of County from February 2012 to February 2013.
What Does History Tell Us?
The two sides have been regular foes in recent years, and there isn't a great deal to sepa-rate the club's respective records.
Notts slightly edge a head-to-head comparison having picked up 17 wins compared to United's 12, while only three games have ended in draws.
Recent form seems to favour Untied, who have won four of the last six meetings between the two, including a 5-0 win at Meadow Lane on the final day of the 2015/16 season.
There's Usually Goals
We predicted goals against Wycombe on Tuesday evening, and similarly the games between United and County seem to produce more high-scoring affairs.
The last ten meetings between the two have seen 34 goals, an average of 3.4 per game, in what have been some truly entertaining encounters.
Could we be set for more of the same at Brunton Park this weekend?
Watch highlights of last season's 3-2 away victory at Meadow Lane here:
+ Matt Tootle - A product of Crewe's renowned academy system, Tootle spent 16 years at Gresty Road before moving on to Shrewsbury in 2015. He later made the move to Meadow Lane where he has quickly become a fans' favourite - thanks in part to his slug goal celebration. Versatile across the back and in midfield, Tootle is experienced at this level and is certainly a reliable performer.
+ Jorge Grant - The lively attacking midfielder shone during a loan spell from city rivals Nottingham Forest last year, and Nolan managed to tempt the 22-year-old back on a similar deal this season. Quick, pacy and with an eye for goal, Grant has already shown his ability this season with seven goals in his 14 games. He will need to be watched carefully.
+ Jon Stead - An experienced head in the Magpies' attack, Stead has built up a strong partnership with fellow ex-Premier League striker Shola Ameobi. The former Blackburn and Sunderland man was a key player in Notts' survival last season and has carried his form into the new campaign having netted three all ready while laying on plenty of opportunities for those around him.
MATCH PREVIEW: The Blues head to Oldham on Saturday
Carlisle are back to league action at the weekend as the make the trip to Oldham to face the Latics.
MATCH PREVIEW: United host Cardiff in FA Cup third round replay
It's the Blues against the Bluebirds for the second time in the space of 10 days with the sides having not met since March 2001 prior to the FA Cup third-round game at the Cardiff City stadium just...
MATCH UPDATES: Handy information for the visit of Cardiff
MATCH PREVIEW: Plymouth head north at the weekend
It's the longest trip of the season for Plymouth - and away fans are warned that the M6 faces a closure from 8pm on Friday night [10 January] all the way through to Monday morning, which makes getting...
YOUTH: United 1 - 0 Morecambe
United were back in action for the first time in 2020 following last weekend's weather enforced postponement.
INTERVIEW: We're now looking for consistency
United boss Chris Beech spoke to us about the Weekend trip to Oldham as the Blues return to league action following their midweek FA Cup exploits.
GALLERY: Cardiff mascots enjoy their evening
Mascots Connor, Theo, Harry and Reed joined us on Wednesday evening and they got to meet the players and have a look behind the scenes at Brunton Park ahead of the Emirates FA Cup third round replay...
ACADEMY: U11s win Fleetwood Cup
United's U11 side travelled to Fleetwood Town's Poolfoot Farm training complex last weekend and, following some excellent work on the pitch, came away as winners of the Fleetwood Cup.


Tuesday January 3, 2017 | FBorFW Strip Fix For Better or For Worse Comic Strip by Lynn Johnston.
Lynn's Comments: When the content of the comic strip began to bore me a bit, I tried to introduce some angst into my writing. This story was based on a real situation, but I changed the details so that the people involved never knew it was their story.
This entry was posted in Uncategorized on January 3, 2017 by stripfix.


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Hitler's ebook Black : How the Nazis Ruled Europe. New York, NY; Toronto: ideology. McElligott, Anthony; Kirk, Tim; Kershaw, Ian( 2003). elections in Honour of Sir Ian Kershaw.
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Smith, Joseph; Davis, Simon( 2005). The A to Z of the Cold War. Lanham, MD: Get the facts Press. Bloodlands: Europe between Hitler and Stalin. Sonderbehandlung erfolgt durch Strang '. strongholds for National pdf enfance et psychopathologie( in whole). Sontheimer, Michael( 10 March 2005). Germany's Nazi Past: Why Germans Can Never Escape Hitler's Shadow '. Hitler and the Power of Aesthetics. New York, NY: form Press. broken 24 September 2018. Bundesrepublik Deutschland '( PDF)( in long). temporary from the political( PDF) on 26 September 2007.
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It's that loving hand upon your face that keeps you in your place.
For what you cruelly sow...... They called you lady tyranny.
To drown me at birth, a task never done, pray not to wake to the nightmare she spun.
For what you cruelly sow...... They call you lady tyranny.
Parental wounds seep a hideous scar.
For what you cruelly sow...... They blamed you lady tyranny.
La letra de canción de They Called Her Lady Tyranny de Sarah Jezebel Deva es una transcripción de la canción original realizada por colaboradores/usuarios de Coveralia.
Sarah Jezebel Deva They Called Her Lady Tyranny lyrics is a transcription from the original song made by Coveralia's contributors/users.


text:
Ку́зъёль — река в России, протекает в Сосногорском районе Республики Коми. Устье реки находится в 115 км по правому берегу реки Лемъю. Длина реки составляет 22 км.

Этимология гидронима
Кузъёль в переводе с коми — «Длинный ручей». От куз — «длинный» и ёль — «ручей», «лесная речка».

Данные водного реестра
По данным государственного водного реестра России относится к Двинско-Печорскому бассейновому округу, водохозяйственный участок реки — Печора от водомерного поста у посёлка Шердино до впадения реки Уса, речной подбассейн реки — бассейны притоков Печоры до впадения Усы. Речной бассейн реки — Печора.

Код объекта в государственном водном реестре — 03050100212103000061180.

Примечания

Притоки Лемъю
Реки Сосногорского района

redpajama_set_name: RedPajamaWikipedia


text:
ExtraTorrent loses control of 3 major mirror domain names
Three Mirror Domain Names Lost By ExtraTorrent
Following an outside complaint, ExtraTorrent, one of the world's largest torrent indexes, has lost control over many of its important mirror domain names. According to the site's operator, he has been locked out of his domain registrar's control panel. Now, extra.to and extratorrent.site are the new official mirrors, as recommended by the site.
Trailing behind The Pirate Bay, ExtraTorrent is the second largest torrent site with millions of daily visitors.
Several entertainment industry groups put pressure on hosting companies and domain name services to take action against ExtraTorrent due to its popularity.
Consequently, ExtraTorrent ended up losing control of three domain names used for its official mirror sites over the past several days. Thus, extratorrent.rocks, etproxy.top and extratorrent.date are no longer available following a complaint from rightholders.
The site's operator mentioned Subreg.cz as the culprit while speaking to TorrentFreak. The Czech domain registrar apparently locked the torrent site out of its control panel while the domains stopped resolving.
The registrar allegedly suggested the torrent site to take the matter to court, as it said that there's nothing it could do to resolve the situation.
"We don't have access to the three domain names anymore. Subreg recommended us to go to court to resolve this issue, and ignored our requests," ExtraTorrent's SaM says.
While this sounds like a typical registrar domain suspension, there is definitely something more to this. Oddly, the registrar informed TorrentFreak that they are not responsible for the domain problems.
"These domain names are not blocked from our side. We got a complaint which we sent to the account holder," a Subreg spokesperson says, noting that they functioned in agreement with ICANN rules.
The comment above clearly suggests that some higher authority is behind this decision. On the other hand, the domain WHOIS information doesn't show any typical registry or registrar suspension notices. The domains have merely been stripped of their "a records," which means that they are not responding.
Even though ExtraTorrent lost three important mirror domains, the main ExtraTorrent.cc domain is still working as it is registered elsewhere. The same applies to many other official mirror domains.
ExtraTorrent has started redirecting all their mirrors to extratorrent.site and extra.to, which are now the official backups. The site's operator endorses the latter, as it's not blocked anywhere, yet.
When TorrentFreak asked the registrar to provide additional information about the discrepancy, they responded by saying that they only reveal details to the domain owner.
Source: TorrentFreak
Registry Suspends Major Torrent Site EZTV's Domain


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O.C. 13-Year-Old Has Raised $25,000 to Combat Homelessness Through Lemonade Stand
Posted 2:10 PM, August 11, 2017, by Chip Yost, Updated at 04:05PM, August 11, 2017
A 13-year-old girl who has raised thousands of dollars to help homeless people was hoping to raise even more at a lemonade stand fundraiser in Los Alamitos on Friday. Chip Yost reports from Los Alamitos for the KTLA 5 News at 1 on Aug. 11, 2017.
Correction: A previous version of this post incorrectly stated the girl's age.
Topics: los alamitos
Kids Sell Lemonade in L.A. Park to Help Detained Migrants, Asylum Seekers
91-Year-Old Man Killed, 8 Others Hurt in Long Beach 2-Car Crash
First Woman Appointed to Lead U.S. Army Infantry Division Will Take Command at O.C. Base This Month
Santa Anita Track Closes for the Season Sunday With 30 Horse Deaths, Hall of Fame Trainer Banned
Santa Anita Horse Death Toll Nowhere Near Track's Deadliest Year
Nation/World News Sports
Jim Bouton, Former New York Yankees Pitcher and 'Ball Four' Author, Dies at 80
24th Annual Wienerschnitzel Wiener Nationals at Los Alamitos Race Course
Major Tracks to Ban Race-Day Use Of Anti-Bleeding Medication; Protestors Gather at Santa Anita Racetrack Meeting
Man Charged With Using E-Scooter to Attack 75-Year-Old in Downtown L.A.
Pursuit Ends in Crash, Killing Woman and 5 Dogs in Long Beach
Funeral for Slain L.A. Sheriff's Deputy Joseph Solano to Be Held Monday
ICE Expected to Begin Immigration Raids Targeting Families in 10 Cities, Including L.A., on Sunday
MS-13 Member Sentenced to Life in Prison for Kidnapping, Rape, Murder of 13-Year-Old Whittier Girl


text:
Always A Free Consultation: 619-908-1563
Eric M. Overholt, Esq.
Common Workplace Injuries
Do I Have To Pay For A Lawyer?
Help For Injured Workers In California
How To Save Evidence For Your Claim
Injured At Work? Here's What To Do.
Overview Of The Work Comp Process
The Independent Medical Review Process
Trials And Appeals
What Happens When Temporary Benefits Run Out?
Workers' Compensation Terminology
Always A Free Consultation
"I will ensure the settlement you are getting is the best possible — and I'm not afraid to go to trial to get it."
– Attorney Eric Overholt, Esq.
Excessive heat may lead to an uptick in workplace injuries
On Behalf of Eric M. Overholt, Esq., Attorney at Law | Aug 2, 2021 | Types of injuries |
I cannot deny that summer in the San Diego area can be brutally hot at times. Still, we see people going to work at construction sites and factories every day in the heat. However, one study has found that when the weather is scorching the number of workplace injuries increases.
The link between hot temperature and work accidents
The study examined 18 years' worth of workers' compensation claims in California and compared these claims to the daily temperature on the date of injury. Workplace injuries rose approximately 9% on days when the temperature reached the 90s. Moreover, workplace injuries rose a whopping 15% on days when the temperature reached the 100s. Hot temperatures affect not just those who worked outside but also those who worked indoors such as in factories or warehouses. Heat was responsible for about 20,000 workplace injuries annually.
What are some injuries workers suffer in the heat?
When I think of heat-related injuries I initially think of heat sickness or heat exhaustion. However, these are not the only injuries related to heat. When it is hot out, workers are more apt to fall, be struck by a vehicle or mishandle heavy equipment. Simply put, heat can impair decision-making.
Learn more about workers' compensation in California
I know just how hard it is to get by after suffering a workplace injury. I understand how difficult it is to pay for medical expenses and living expenses when I cannot work. Fortunately, California's workers' compensation system can help bridge the gap financially following a workplace injury. My website on workers' compensation explains more about what can be done following a workplace injury.
Small injuries can mean big losses for restaurant workers
Tips for living with your work-related injuries
Should you settle your workplace accident third-party claim?
Common injuries that can occur at work
The hazards of work-related RSI
Contact The Firm Today
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CALSPro is dedicated to the education of Process Servers statewide. Stay in the know as we take a look at how you should properly endorse a Summons in this 30-minute online webinar. Space is often limited, so please reserve your spot early!
If you are interested in attending and are not a CALSPro member, please click here to submit your membership application today!
When the Going Gets Tough, Be Nice!
Didn't your mother ever teach you to play nice with others? Well the same can be said in today's business world. We rely on our customers to make our businesses successful. The best way to cultivate and grow your relationships with your customers is quite simple, be nice! In an article written by Kathleen Elkins, she explains how entrepreneur Mark Cuban reflects on this underrated skill.
Entrepreneur Mark Cuban owns the Dallas Mavericks, stars on ABC's "Shark Tank" and is worth an estimated $3.9 billion. If you ask the businessman what it takes to succeed, though, he doesn't just point to work ethic and negotiation skills.
He continued: "I went through my own metamorphosis, if you will. Early on in my career, I was like bam, bam, bam, bam, bam — I might curse. I might get mad. And then I just got to the point — I wouldn't have wanted to do business with me when I was in my 20s.
Science backs his claim that soft skills can boost your career: Studies show that a high level of emotional intelligence, or EQ, can make you wealthy and successful.
You may have heard me say how I am truly proud to serve as CALSPro's president once or twice. It's great to give back to an association that has promoted, protected and preserved our industry. This noble work continues today as your dedicated board of directors and committee chairs continue moving the association forward and are hard at work.
Your newsletter and website committees are sending out weekly blogs full of relevant and helpful information. Your education committee recently had its first CCPS webinar which was offered and saw 27 attendees. A special thanks to Mark Manchester and Andrew Gowing for their efforts getting this new medium off the ground. Our new CALSPro app is up and live for anyone to download through the App Store or Google Play thanks to our technology committee and CALSPro HQ. It is a great tool for yourself, office and field staff alike. We also implemented on-line registration renewal, focusing on making the registration process easier for all, thanks to your membership committee.
We are also diligently working on new networking opportunities by forming strategic alliances with industry related associations. We hope that by sharing information with these groups, CALSPro members will see a direct benefit in the coming months.
During our renewal process I heard from a couple members concern that CALSPro was for the "big boys". As, I sat at this weekend's board meeting I gave this great thought. I looked around the room and realized that of the 10 seats of the board of directors, half were seats filled by small companies. I won't name them here but encourage you to take a look for yourself and discover how diverse our association really is. Keep in mind, most large companies started out as small companies.
I am continually reminded that CALSPro is our best form of insurance. If not for the efforts of CALSPro over the past 50 years we may not have an industry. CALSPro has defeated numerous adverse legislative bills that would have been disastrous for our industry. CALSPro is the ultimate watchdog who has your back.
I would ask that, should you have any questions or concerns about the association, the direction of the association or other CALSPro related topics, to reach out to you area governors. The area governors, members of the board of directors and your executive board would all love to hear from you.
I am looking forward to a great rest of 2019.
This Request for Dismissal will be received through eFiling and processed manually by the court. A copy will be sent to the address on the dismissal once processed. Any other documents in this transaction have been processed electronically.
The temporary process will remain in place until the backlog has been alleviated. Again, this is just for unlimited civil cases in the Stanley Mosk Courthouse.


text:
FCC Releases Draft Internet Freedom Order
By Michael C. Sloan, John D. Seiver, James F. Ireland, Maria T. Browne, and K.C. Halm
The wheel that is U.S. policy on "net neutrality" has taken another turn. On November 22, 2017, the FCC released a draft of the Internet Freedom Order,1 which, when effective, will reverse the Commission's 2015 Open Internet Order (now referred to as the "Title II Order").
As recounted in previous DWT Alerts,2 the Title II Order's finding that broadband Internet access service (BIAS) is a "telecommunications service" and, therefore, subject to "common carrier" regulation under Title II of the Communications Act, reversed almost 15 years of FCC precedent which held exactly the opposite – i.e., that BIAS is an "information service" and specifically exempt from Title II regulation. Included with the Title II Order's reclassification of BIAS were a number of regulatory obligations, including prohibitions on blocking, throttling, and paid prioritization, as well as affirmative disclosure requirements (known as the "Transparency Rule") and a multi-factor "Conduct Standard" which the FCC planned to apply prospectively on a case-by-case basis.
With the Internet Freedom Order, the FCC has returned to its pre-2015 conclusions. It is reinstating the information service classification and, with it, jettisoning many of the regulatory obligations established by the Title II Order, including the explicit bans on blocking, throttling, and paid prioritization and the general conduct standard. What will remain is a modified "transparency rule" that will require that any blocking, throttling, and paid prioritization be clearly explained in a publicly available "terms of service document that will be subject to enforcement by the FTC.
This advisory summarizes the analysis in the Internet Freedom Order (which consists in large part of a repudiation of the Title II Order) and discusses some of the implications of the reclassification. It is organized as follows:
Part I addresses the legal basis for the reclassification, some of the policy considerations cited by the FCC in support of the reclassification, and the extension of the reclassification to mobile broadband.
Part II addresses the new "light touch" enforcement framework and the FCC's rationale for eliminating the previous requirements.
Part III addresses the policy impact of the order on the following issues:
a. Wireline and wireless infrastructure;
b. Internet subscriber privacy and data security;
c. Preemption of state and local authority;
d. disability access; and
e. Internet traffic exchange arrangements.
I. Reclassifying Broadband Internet Access as an Information Service
A. Background
The specific legal question decided in the Internet Freedom Order is whether broadband internet access service (BIAS) is an "information service" or a "telecommunications service" under the Communications Act.3 In plain English, "telecommunications" is the transmission of data without change in form or content (i.e., without computer processing). A "telecommunications service" is the offering of "telecommunications" for a fee. By definition, telecommunications services are "common carrier" services subject to "public utility" regulation under Title II of the Act. An "information service," by contrast, is, generally speaking, a computer processing service accessed via telecommunications and is only subject to regulation by the FCC – to the extent they are regulated at all – under the general powers conferred on the FCC by Title I of the Act. The FCC has determined that "information services" and "telecommunications services" are "mutually exclusive" designations. Information services are specifically exempt from Title II common carrier regulation.
Although these definitions were codified by the Telecommunications Act of 1996, their history dates to the late 1970s, when remotely accessed data processing services first began to emerge on the scene. Telephone companies – then there was basically only one, AT&T – wanted to enter the business. Regulators were concerned, however, that the phone companies would use their market power over transmission (thought to be a "natural monopoly") to disadvantage and stifle the burgeoning data processing firms, who needed transmission services to offer their own services and against whom the phone companies planned to compete.
To address this concern, the FCC, in a series of decisions known as the Computer Inquiries, permitted the phone companies to enter the market for data processing services, but conditioned that entry on the requirement that phone companies offer transmission pursuant to tariffed rates, terms and conditions that were subject to oversight by the FCC. Thus was born the distinction between "basic services" (i.e., transmission), which phone companies had to offer to firms providing "enhanced services" (i.e., data processing), which Congress renamed "telecommunications services" and "information services," respectively.4
B. The First Classification Orders
The FCC first classified broadband Internet access as an information service in the 2002 Cable Modem Order. In a series of orders that followed, the FCC extended the information service classification to BIAS services offered by telephone companies (i.e., DSL and other wireline services), wireless, satellite, and "broadband over powerline." (Together, we call these the "Classification Orders."5)
The FCC determined that Internet access is not a telecommunications service, first, because it involves "generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information ...". One example of the data processing performed by broadband ISPs is the use of the Domain Name System (DNS) to route traffic on the Internet. DNS translates human language (e.g., the name of a website or an email address) into the numerical data (an IP address) that computers can process in order to route Internet traffic to and from websites and other end-points selected by the user. Thus, the information retrieval function and capabilities of ISP-provided DNS is a core feature of Internet usage. The FCC also looked at various consumer-facing services that BIAS providers offer, such as email (which is clearly an information service) as supporting the information service designation for BIAS services.
The principal innovation of the Classification Orders was the FCC's determination that BIAS "is a single, integrated service that ... does not include a[] [separate] offering of telecommunications service to subscribers."6 In other words, while the Computer Inquiry orders assumed – and largely required – that phone companies offer transport services separately to their data processing competitors ("unbundled" transport), the Classification Orders imposed no such requirement. These determinations were affirmed by the Supreme Court in the Brand X decision.
The difficulty that the information service designation posed for the FCC, however, was that it made enforcing certain expectations that the agency had of BIAS providers – no blocking, no throttling, etc. – legally difficult. The courts invalidated several FCC enforcement efforts, each time sending the matter back to the FCC for further development.
C. The Statutory Analysis of the Internet Freedom Order and its Rejection of the Title II Order
And that is where the "net neutrality" debate stood in 2015, when the FCC, then led by Chairman Wheeler, ruled, in response to the (then) most recent D.C. Circuit remand, that BIAS is a telecommunications service and, therefore, subject to various common carrier obligations under Title II (most of which the FCC simultaneously announced that it would forbear from enforcing).
The FCC's reasoning in the Title II Order, which rejects the analysis in the Classification Orders, is a large part of the Internet Freedom Order. For example, the Title II Order took issue with the Classification Orders' determination that DNS is one of the characteristics that makes BIAS an information service. Instead, the Title II Order ruled that DNS is a tool that BIAS providers use to manage their networks, and therefore falls within the "management exception" to the information service classification.7 The Internet Freedom Order rejects this analysis, ruling that, "the Title II Order erred in finding that Domain Name System (DNS) functionalities fell within the telecommunications systems management exception to the definition of 'information service.'" To the contrary, the Internet Freedom Order finds that "the record reflects that little or nothing in the DNS look-up process is designed to help an ISP "manage" its network; instead, DNS functionalities 'provide stored information to end users to help them navigate the Internet.'"
The dialog between the Title II Order and the Internet Freedom Order on the significance of customer-facing services like email is also instructive. The Title II Order ruled that BIAS providers' email offerings could not justify an information service classification (contrary to the Classification Orders' determination) because end-user customers do not always use their ISP's email services; indeed, most do not, opting instead for the email services of edge providers like Google and Microsoft. The Internet Freedom Order, however, rejects this analysis as contrary to the statute, which specifically defines an information service as "the offering of a capability for generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information via telecommunications."8 The fact that not all customers avail themselves of all the "capabilities ... offer[ed]" by BIAS providers is irrelevant under the statute. It is the "offering of a capability" that matters.
This same statutory analysis underlies the Internet Freedom Order's rejection of the Title II Order's finding that customers view BIAS as a separate offering of telecommunications because consumers largely use BIAS to access content from third parties unaffiliated with the ISP. The Internet Freedom Order rejects this analysis as incomplete, finding that the defining characteristic of BIAS is the "capability" it offers "to interact with information online," which, in combination with other information processing capabilities (e.g., DNS, e-mail) makes it an information service.
D. Policy Considerations of the Internet Freedom Order
Finally, the Internet Freedom Order cites a number of policy considerations in support of the information service classification.
Title II Imposes Substantial Costs. The Internet Freedom Order concludes that the telecommunications classification reduced ISP investment in the network and hampered innovation due to regulatory uncertainty, citing ISP capital investment increasing each year from 2009 to 2014 but declining in 2015 and 2016 as ISPs delayed or shelved new projects and business models.
The order also asserts that the increased compliance costs and regulatory burdens associated with common carrier / Title II regulation forced smaller ISPs, which often serve rural and/or lower income users, to divert capital and attention away from expansions and upgrades and increased their cost of capital. The order predicts reclassification will help these providers expand into unserved areas. Finally, the order finds no evidence that Title II regulation has spurred edge provider investment.
More apt enforcement mechanisms. The Internet Freedom Order also concludes that Title II enforcement mechanisms are not the best tools for safeguarding the interests of internet "open-ness." As described more fully below, the order scraps the ex ante prohibitions on blocking, throttling, and paid prioritization – and the Commission's ability to enforce those prohibitions – and returns jurisdiction to the Federal Trade Commission (FTC) and other consumer protection mechanisms to enforce the transparency requirements," which remain largely in place. The order predicts that the FTC's authority to prohibit unfair and deceptive practices will address potential harms to consumers and will better serve the dynamic Internet ecosystem than utility-style regulation for the following reasons:
Antitrust's case-by-case, content-specific, ex post analysis will allow innovative new business arrangements to emerge, which will be evaluated based on real-world effects rather than a regulator's ex ante predictions;
The "rule of reason" will strike a better balance in protecting an open Internet while allowing "permissionless innovation;"
A focus on protecting competition and consumers means that the law will not condemn practices that benefit consumers; and
The same laws will apply to all sectors of the economy, including all Internet actors, which avoids the regulatory distortions of Title II.
Finally, the Internet Freedom Order concludes that common carrier regulation of BIAS is, to quote the order, "a solution in search of a problem." The order finds that Title II imposes significant costs on ISPs based on only sparse evidence of harms. In the two decades as an information service under Title I, the Internet flourished and problematic conduct was rare. The order underscores that while the Title II Order was premised on the concern that ISPs would exercise their market power to distort economic efficiency and harm users, data indicates these providers face pressures through direct and inter-modal competition. At lower speeds, competition is widespread for wireline ISPs; therefore, the primary market failure rationale for Title II is absent. Furthermore, mobile wireless ISPs face even greater competition than wireline ISPs. Finally, the order points out that edge providers are not dependent on gaining access to any single ISP, noting, for example, that Comcast, the largest ISP, serves only 25 percent of all wireline broadband connections. Larger edge providers have a ubiquitous national presence and countervailing market power that the FCC predicts will reduce the likelihood of inefficient outcomes due to ISP market power.
E. Information Service Classification Extended to Mobile Broadband
Prior to Title II Order, the Commission classified mobile BIAS as a private mobile service which, as a consequence, was not subject to common carrier regulation. Based on some fancy statutory footwork, the Title II Order ruled otherwise, holding that mobile BIAS is a commercial mobile service, thus subjecting mobile BIAS to regulation as a common carrier service. The Internet Freedom Order returns mobile BIAS to classification as a private mobile service and thus removes mobile BIAS from common carrier style regulation.
II. New Enforcement Mechanisms
A raison d'etre for the Title II Order's reclassification of BIAS as a telecommunications service was the D.C. Circuit's ruling that the FCC's previous restrictions on blocking, throttling and paid prioritization effectively constituted common carrier regulation that could only be enforced pursuant to Title II.9 With the reclassification back to information services, those prohibitions are once again effectively unenforceable and have been scrapped by the Internet Freedom Order. The order also eliminates the general Internet conduct standard.
In addition to the legal imperative described in the previous paragraph, the order provides three overarching reasons for the FCC's action: first, the FCC reasons that the transparency rule, when coupled with the state of BIAS competition, and antitrust and consumer protection laws, obviates the need for conduct rules by achieving comparable benefits without the associated costs; second, the order generally finds that the costs of each rule outweigh any potential benefits; and third, the Commission finds that the record does not identify any legal authority to adopt the conduct rules for all ISPs.
The order relies significantly on the fact that its newly-adopted transparency rule will achieve greater benefits than the conduct rules without the associated costs. The order states that "public attention, not heavy-handed Commission regulation, has been most effective in deterring ISP threats to openness." Further, the order predicts that the transparency rule amplifies the power of antitrust law and the FTC to deter and remedy behavior that harms consumers. "Transparency [] leads to openness and achieves comparable benefits to conduct rules." Finally, the elimination of the conduct rules will substantially reduce the compliance burdens imposed on ISPs, and will consequently result in a substantial reduction in costs associated with the rules.
The Internet Freedom Order's Critique of the Title II Order's Enforcement Rules
a) The Internet Conduct Standard
The order criticizes the now-eliminated Internet conduct standard as vague and little more than a rule that "simply warns carriers to behave in accordance with what the Commission might require, without articulating an actual standard." Consequently, the order posits that the Internet conduct standard created uncertainty, which has contributed to the recent reduction in network investment and service-related innovation described above. To illustrate, the order cites the uncertainty created by the Wireless Bureau's 13-month investigation into zero-rating practices, during which few, if any, new such programs were rolled out, as illustrative of the chill on innovation created by uncertainty surrounding the standard.
b) Paid Prioritization
The Internet Freedom Order declines to adopt a ban on paid prioritization. The order states that the transparency rule, along with the enforcement of the antitrust and consumer protection laws, addresses the concerns regarding paid prioritization raised in the record and that antitrust law "would only allow [ ] ISPs to engage in pro-competitive paid prioritization practices." Further, the order predicts that elimination of the rule will spur innovation and experimentation, and result in better allocation of network costs. In particular, the order predicts that elimination of the paid prioritization rule will result in the development of innovative Quality of Service arrangements that are necessary for telemedicine and connected vehicle technologies. Furthermore, the order reasons that elimination of the rule will result in economic efficiencies that benefit consumers, such as differential usage-based pricing models (for consumers that use bandwidth intensive applications like Netflix) or that shift costs to the edge providers themselves.
c) Blocking and Throttling
The order also eliminates the blocking and throttling rules based on the view that the transparency requirement will prevent the potential harms that could be caused by blocking or throttling. For example, any attempt by an ISP to block or throttle content would likely be met with a fierce consumer backlash. Furthermore, the order notes that numerous ISPs have publicly pledged not to block or throttle content that consumers choose, which are reflected in the providers' transparency disclosures, and that that violations of those disclosures will give rise to enforcement by the FTC and the consumer protection laws. The "transparency requirements, rather than conduct rules, are the most effective means of preserving Internet openness."
d) The Transparency Requirements
The Internet Freedom Order reaffirms the Commission's 2010 commitment to baseline transparency requirements applicable to both wireline and mobile ISPs but scales back the enhancements added in 2015.10 All ISPs will continue to be required to publicly disclose information regarding their network management practices, network performance characteristics and commercial terms of the broadband internet access services they offer "sufficient for consumers to make informed choices."
Importantly, the Commission has determined that these latest transparency requirements work hand-in-hand with restoring the FTC's jurisdiction over BIAS providers as a result of reclassification. FTC oversight and the disclosure rules obviate the need for the conduct rules (discussed above) that are being eliminated in the order." We find that the conduct rules are unnecessary because the transparency requirement we adopt, together with antitrust and consumer protection laws, ensures that consumers have means to take remedial action if an ISP engages in behavior inconsistent with an open Internet."
Notably, the order does not exempt small providers from any transparency disclosure requirements, in part because they were already subject to the 2010 standards. Thus, if adopted, all wireline and mobile ISPs will be subject to these rules and will be required to disclose on their website, or directly to the Commission, information in the following three categories:
Category 1: Network Management Practices
Blocking. Any practice (other than "reasonable network management")11 that blocks or otherwise prevents end user access to lawful content, applications, service, or non-harmful devices, including a description of what is blocked.
Throttling. Any practice (other than reasonable network management) that degrades or impairs access to lawful Internet traffic on the basis of content, application, service, user, or use of a non-harmful device, including a description of what is throttled.
Prioritization of Traffic. Any practice that directly or indirectly favors some traffic over other traffic, including through use of techniques such as traffic shaping, prioritization, or resource reservation "in exchange for consideration, monetary or otherwise."
Prioritization of Affiliate's Traffic. Notably, the order requires ISPs to disclose and distinguish prioritization techniques applied to all traffic, from those applied to any prioritization that benefits an affiliate. ISPs must also identify the affiliate benefiting from such prioritization.
Congestion Management. Descriptions of congestion management practices, if any. These descriptions should include the types of traffic subject to the practices; the purposes served by the practices; the practices' effects on end users' experience; criteria used in practices, such as indicators of congestion that trigger a practice, including any usage limits triggering the practice, and the typical frequency of congestion; usage limits and the consequences of exceeding them; and references to engineering standards, where appropriate.
Application-Specific Behavior. Whether and why the ISP blocks or rate-controls specific protocols or protocol ports, modifies protocol fields in ways not prescribed by the protocol standard, or otherwise inhibits or favors certain applications or classes of applications.
Device Attachment Rules. Any restrictions on the types of devices and any approval procedures for devices to connect to the network.
Security. Any practices used to ensure end-user security or security of the network, including types of triggering conditions that cause a mechanism to be invoked (but excluding information that could reasonably be used to circumvent network security).
Category 2: Network Performance Characteristics
Service Description. A general description of the service, including the service technology, expected and actual access speed and latency, and the suitability of the service for real-time applications.
Impact of Non-Broadband Internet Access Service Data Services. If applicable, what non-broadband Internet access service data services, if any, are offered to end users, and whether and how any non-broadband Internet access service data services may affect the last-mile capacity available for, and the performance of, broadband Internet access service.
Category 3: Commercial Terms
Price. Monthly prices, usage-based fees, and fees for early termination or additional network services.
Privacy Policies. A complete and accurate disclosure of the ISP's privacy practices. For example, whether any network management practices entail inspection of network traffic, and whether traffic is stored, provided to third parties, or used by the ISP for non-network management purposes.
Redress Options. Practices for resolving complaints and questions from consumers, entrepreneurs, and other small businesses.
Format and Means of Disclosure
The order provides two options for disclosure: either on a publicly available, easily accessible website (in a manner accessible by people with disabilities), or by direct transmission to the Commission, who will make such disclosures available on its own website. The order eliminates the consumer broadband label safe harbor that was promoted under the Title II Order.
III. Other Issues and Implications
Wireless and Wireline Infrastructure
The reclassification presents issues for infrastructure deployment, which the Commission states in the Internet Freedom Order it intends to address in subsequent proceedings. For example, the Order defers consideration of the impact of the reclassification on wireline and wireless pole attachment rights granted by Section 224 (which applies to telecommunications carriers not providers of information services), stating that to the extent such issues arise, it will consider them in proceedings governing wireline and wireless broadband deployment and access to multiple tenant environments.
The order states that "we are resolute that today's decision not be misinterpreted or used as an excuse to create barriers to infrastructure investment and broadband deployment." The Order recognizes, however, that pole owners and municipalities have aggressively sought to take advantage of broadband deployment by imposing additional charges on what they claim are "unregulated services" – i.e., services not meeting the definition of cable television or telecommunications. The FCC hastened to make clear its position that federal protections still apply to BIAS providers as long as they offer other qualifying services on a commingled basis. For example, it expressly reminds pole owners of their continuing obligation to offer "rates, terms, and conditions [that] are just and reasonable." And, it reiterates that Section 224 protections apply to any infrastructure that provides "both telecommunications and wireless broadband Internet access service." Notably the Commission cautions pole owners that they should not use the reclassification "as a pretext" to increase pole attachment rates or "an excuse to create barriers to infrastructure investment and broadband deployment."
The order also addresses the deployment of wireless infrastructure. It reaffirms the Commission's decision in its 2007 Wireless Classification Order, in which the FCC first classified wireless broadband Internet access service as an information service, and established that the limitations on local government authority contained in Section 332(c)(7)(B),continues to apply where the wireless infrastructure provides both telecommunications and wireless broadband Internet access service. The order states that this "clarification will alleviate concerns that wireless broadband Internet access providers not face increased barriers to infrastructure deployment as a result" of the reclassification. The Internet Freedom Order also explains that the Section 332(c)(7) protections apply to facilities, including DAS or small cells, that are deployed for the provision of personal wireless services, even where such facilities also may be used for broadband Internet access services.
Addressing both wireline and wireless deployment, the order states that the FCC "will closely monitor developments on broadband infrastructure deployment and move quickly to address barriers in a future proceeding if necessary."
Privacy and Data Security
When BIAS was reclassified as a Title II telecommunications service in 2015, the FTC Act's common carrier exemption shifted consumer privacy protection from the FTC to the FCC. As a result, in 2016 the Commission, relying on its authority under the Customer Proprietary Network Information ("CPNI") provisions in 47 U.S.C. § 222, adopted detailed privacy rules governing the provision of BIAS. Shortly after the change in administration this year, the Commission stayed those CPNI rules, which were ultimately repealed under the Congressional Review Act, thus prohibiting the FCC from implementing "substantially similar" rules in the future.
Many consumer advocates have argued that the repeal of the FCC's privacy rules created a regulatory "gap" in online consumer privacy. However, in the absence of specific rules, broadband privacy has remained subject to the general protections in Section 222, which the FCC committed to enforce so long as BIAS remained classified as a Title II telecommunications service. By now moving BIAS back to a Title I information service, the Commission has stated its intent to "return jurisdiction" to the FTC "to apply its extensive privacy and data security expertise to provide the uniform online privacy protections that consumers expect and deserve." However, the privacy protections of Section 222 and the formerly reinstated CPNI rules will continue to govern traditional Title II voice services, as well as interconnected VoIP service.
In restoring the FTC's jurisdiction, the order also rejects arguments that a recent Ninth Circuit decision "precludes FTC oversight of non-common carriage activities of common carriers" which would prevent the FTC from overseeing activities of ILECs and other entities that provide common carrier services in addition to BIAS. That panel decision has been vacated and is awaiting a decision of the full court following argument on rehearing en banc last September. In the event the full court reverses the panel decision, Ninth Circuit law will be consistent with precedent from the Second and Fourth Circuits that precludes FTC jurisdiction over common carriers only with respect to the actual provision of common carrier services. If not reversed, the Circuit split would make the case ripe for Supreme Court review.
Another wrinkle that will need to be ironed out in coming months is the effect of the Order's preemption of any and all "state and local laws that interfere with the federal deregulatory policy restored in this order." In reaction to Congress' repeal of the FCC's rules, many state and local governments attempted to impose similar privacy rules in their respective jurisdictions. Most of the bills introduced in 2017 were brought as emergency measures or were introduced late in the state legislative sessions, and failed as a result of their rushed nature. It is widely expected that the 2018 legislative season will see renewed state efforts, which will have to be reconciled with the FCC's preemption language, the grant of rights to state and local authorities in other statutes (including within other sections of the Communications Act), and will likely trigger litigation.
Preemption of State and Local Regulations
In an effort to preclude state or local governments from seeking to reimpose provisions of the Title II Order, the Commission "preempt[] any state or local measures that would effectively impose rules or requirements that we have repealed or decided to refrain from imposing in this order or that would impose more stringent requirements for any aspect of broadband service that we address in this order," including "common-carriage requirements akin to those found in Title II of the Act and its implementing rules .…" Under established caselaw, the commission's policy of non-regulation is entitled to as much preemptive effect as its regulations are. "Nothing in the Act suggests that Congress intended for state or local governments to be able to countermand a federal policy of nonregulation or to possess any greater authority over broadband Internet access service than that exercised by the federal government."
The Commission has long preempted state regulation of information services. The Commission based its preemption authority on prior findings in the Title II Order that BIAS is jurisdictionally interstate; that it would be "impossible or impracticable for ISPs to distinguish between intrastate and interstate communications" and because state or local regulation would "interfere" with the new order's purposes, preemption is authorized.
Unstated – but apparent – issues concern the extent of state and local government's authority over broadband infrastructure and privacy. The Commission made clear its intent to preempt any effort to impose rules that have been repealed, but also recognized that state law on "fraud, taxation and general commercial dealings" would still apply if they do not interfere with the Commission's deregulatory objectives. Similarly states that have certified to regulate pole attachments under 47 U.S.C. § 224 would continue to do so, as well as designate eligible telecommunications carriers and adopt universal service policies. Other proceedings governing wireline and wireless deployment may be where the Commission would take further action.
The order downplays the impact of its reclassification on disability access, emphasizing that the Twenty-First Century Communications Video Accessibility Act of 2010 ("CVAA") and implementing regulations independently applied certain accessibility obligations to broadband Internet access services regardless of whether BIAS is classified as a telecommunications or information service. The order reiterates the FCC's prior conclusion that ACS equipment and services already must ensure that any incorporated browsers are accessible to persons with disabilities. Likewise, it reminds that Section 718 expressly mandates accessibility for mobile browsers. The order goes on to state that Section 710 of the Act addressing hearing aid compatibility applies regardless of any action taken in the Internet Freedom Order. Consistent with its approach to pole attachment regulation, the order provides that to the extent that any other Internet-related accessibility issues arise, it will address them in separate proceedings pursuant to its specific authority to regulate disability access.
Internet Traffic Exchange Agreements
The Internet traffic exchange market historically functioned and developed without any significant regulatory oversight. In the Internet's infancy, ISPs and edge providers largely paid third-party backbone service providers for transit, which connected upstream to a Tier 1 backbone service provider that enabled access to the full Internet. Recently, however, edge providers increasingly used direct connections with ISPs, rather than transit, to increase the quality of their service. In the Title II Order the Commission applied eight different sections of Title II to traffic exchange between ISPs and edge providers or their intermediaries, which created a complicated regulatory framework governing these agreements. By reclassifying BIAS as an information service, the Internet Freedom Order restores the Internet traffic exchange to the free market framework that the Internet developed within for several decades.
In the absence of rigid regulation of Internet traffic exchange arrangements, innovative and alternative exchange arrangements are likely to develop. From 2005 to 2015 the cost of Internet transit fell over 99 percent on a cost-per-megabit basis largely due to parties utilizing direct interconnection arrangements that benefited consumers by reducing congestion, increasing speeds, and housing content closer to consumers. The Commission expects the development of alternative Internet traffic exchange arrangements and concludes that removal of the Title II utility-style regulation from the Internet traffic exchange market will spur further innovation in this market.
Furthermore, the deregulation of Internet exchange traffic will also eliminate the asymmetrical regulatory treatment of parties to Internet traffic exchange arrangements. The Open Internet Order imposed a one-sided interconnection duty upon last-mile ISPs, which reduced incentives to share costs between ISPs and upstream middle-mile networks, transit networks, content providers, and edge providers. Restoration of the regulatory parity among these sophisticated commercial entities will allow the parties to more efficiently allocate costs arising from increased demands on the network.
While the Order lifts the Title II utility-style regulation from the Internet traffic exchange market, the Commission is quick to note that there are several factors in place that will constrain any anti-competitive behavior by ISPs. In particular, the Commission points to antitrust laws and consumer perception of businesses as two factors that will severely constrain ISP behavior. Regardless, the action taken by the Commission in the draft Order should lead to an innovative Internet traffic exchange market that will ultimately benefit consumers.
1 Although released as a draft, we expect that it will be adopted by the FCC with few, if any, changes. We therefore refer to the draft order as the Internet Freedom Order or "the order" with that expectation. To the extent that any changes are made to the order between now and final release, we will update this advisory accordingly.
2 DWT's analysis of the 2015 Open Internet / Title II Order can be found here. For a comprehensive discussion of the "net neutrality" debate as it stood in 2011, see here. Many of the firm's advisories on the issue can be found here.
3 Section 3 of the Act defines an "information service" as "the offering of a capability for generating, acquiring, storing, transforming, processing, retrieving, utilizing, or making available information via telecommunications, and includes electronic publishing, but does not include any use of any such capability for the management, control, or operation of a telecommunications system or the management of a telecommunications service." 47 U.S.C. § 3(24). A "telecommunications service," by contrast, is "the offering of telecommunications for a fee directly to the public, or to such classes of users as to be effectively available directly to the public, regardless of the facilities used." Id. § 3(53). Finally, "telecommunications" – a term used in each of the prior two definitions – is "the transmission, between or among points specified by the user, of information of the user's choosing, without change in the form or content of the information as sent and received." Id. § 3(50).
4 The statutory phrases actually borrow from the nomenclature used by the court supervising the break-up of AT&T.
5 See this DWT advisory for analysis of the first of these orders, the 2002 Cable Modem Declaratory Ruling.
6 Cable Modem Order ¶¶ 38-39.
7 See 47 U.S.C. § 253(24) (definition of "information service," providing that information service "does not include any use of [a telecommunications capability] ... for the management, control or operation of a telecommunications system or the management of a telecommunications service").
8 47 U.S.C. § 153(24).
9 Although the court did suggest that the FCC might be able to achieve the same or similar results pursuant to authority under Section 706 of the Act, the Title II Order ultimately did not rely on that theory. The Internet Freedom Order goes further and finds that Section 706 is hortatory only and not an independent grant of regulatory authority.
10 The order also eliminates certain network performance disclosure requirements that were imposed by the Title II Order, including: packet loss, geographically specific terms, network performance during "peak" usage, and monthly or promotional rates for service. As described below, the order does require providers to disclose service technology, expected and actual access speed and latency, and the suitability of the service for real-time applications.
11 Reasonable network management is defined as a practice "appropriate and tailored to achieving a legitimate network management purpose, taking into account the particular network architecture and technology of the broadband Internet access service."