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Wednesday, January 17, 2007

IP address matching in the crosshairs

Here's an appeal I like. First, I just don't see words like "abrogate" often enough. But what I like even better is that a law firm has finally sunk its teeth into the SLD's denial of applications when the Form 470 is posted from an IP address that is identical to the IP address that a vendor invoice has been submitted from. I'm happy about that because it gives me hope that instead of just granting a waiver, the FCC will actually forbid denial of applications based solely on IP address matching. Because matching IP addresses does not prove a rule violation. The appeal lists something like 5 reasons, but for me, there are two:
  1. This technique is basically the same as the recently repudiated "pattern analysis." While a matching IP address certainly suggests wrongdoing, it does not prove wrongdoing. I'm all for the SLD using these techniques to decide who gets a Selective Review, but not for denying applications outright. I can come up with all kinds of scenarios where the IP addresses match, but no rule has been broken. Yes, they are all unlikely scenarios, which is why I think matching IP addresses should raise suspicion. But suspicion is not guilt.
  2. IP address matching is technically imprecise. Since On-Tech's Web site and email (and this blog) are externally hosted, we have no use for a static IP address, so we didn't pay extra to get one. That means that our ISP can change our IP address at any time. An IP address that had at one time been assigned to us could later be assigned to a service provider.

Whichever SLD employee thought to compare IP addresses from 470s and SPIs should get a raise; it's a good way to red-flag applications. But whoever decided it was enough information to deny applications should take a cut in pay.

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